Hotel Kingkade v. Commissioner
United States Tax Court
Petitioner, upon the facts, held not to be entitled to deduct, as ordinary and necessary business expenses, the cost of furnishings, equipment, and fixtures it installed in hotels it operated under an oral understanding with the owner thereof.
1Opinion of the Court
OPINION.
Disney, Judge:
On brief, petitioner contends that the lease under which it operated required it to operate first-class modern hotels, which it could not do with worn-out equipment, and that the amounts in controversy constitute ordinary and necessary business expenses under the rationale of Southern Ry. Co. v. Commissioner, 74 Fed. (2d) 887, and Illinois Central R. Co. v. Commissioner, 90 Fed. (2d) 458.
In the Southern Ry. Co. case the court, in discussing a conclusion of the Board of Tax Appeals that deductions for repairs for which an undermaintenance allowance was made by the…
2Cases cited3 opinions
- Boyd-Richardson Co. v. CommissionerUnited States Tax Court · 1945
- Ohio Loan & Discount Co. v. CommissionerUnited States Tax Court · 1944
- Manger Hotel Corp. v. CommissionerUnited States Tax Court · 1948
3Cited by21 opinions
- Ft. Howard Paper Co. v. CommissionerUnited States Tax Court · 1967
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2000
- Public Service Co. v. CommissionerUnited States Tax Court · 1982
- Five Star Mfg. Co. v. CommissionerUnited States Tax Court · 1963
- USFreightways Corp. v. CommissionerUnited States Tax Court · 1999
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