Legal Opinion

Uecker v. Commissioner

United States Tax Court

Decided December 19, 1983No. Docket Nos. 16419-79, 16420-79, 16421-79, 16435-79PublishedCited by 17 opinions

Petitioners purchased a cattle ranch which consisted of a small amount of lands in fee simple, various physical improvements, and a grazing lease and license with finite durations covering adjacent State and federally owned lands. Pursuant to applicable law, petitioners possessed preferential renewal privileges for an indefinite term concerning the grazing lease and license.

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Petitioners purchased a cattle ranch which consisted of a small amount of lands in fee simple, various physical improvements, and a grazing lease and license with finite durations covering adjacent State and federally owned lands. Pursuant to applicable law, petitioners possessed preferential renewal privileges for an indefinite term concerning the grazing lease and license. Petitioners contend that the allocative portions of the ranch purchase price with respect to the grazing license and lease should be amortized over their stated durations. Held, purchase price of ranch allocated to its…

1Opinion of the Court

Goffe, Judge:

The Commissioner determined deficiencies in the petitioners’ Federal income tax for the taxable years as follows:

Petitioners Docket No. Taxable year Amounts

Kermit and Betty Uecker 16419-79 1976 $5,415.26

Kermit W. Uecker 16420-79 1972 4,773.92

1973 7,142.41

1974 1,090.50

1975 6,089.59

Ann Uecker 16421-79 1972 4,773.92

1973 7,142.41

1974 1,090.50

1975 6,089.59

Jon and Sheridan Hansen 16435-79 1975 29,650.00

1976 21,877.00

After multiple concessions by the parties, the issues for decision are the respective values and useful lives of various components of a ranch (including attendant grazing…

2Cases cited11 opinions

  1. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
  4. Watson v. CommissionerSupreme Court of the United States · 1953
  5. McQuiston v. CommissionerUnited States Tax Court · 1982

6 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. Pyo v. CommissionerUnited States Tax Court · 1984
  2. Seligman v. CommissionerUnited States Tax Court · 1985
  3. Munford, Inc. v. CommissionerUnited States Tax Court · 1986
  4. Kermit and Betty Uecker, Ann Uecker, Jon and Sheridan Hansen v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1985
  5. L.L. Bean, Inc. v. CommissionerCourt of Appeals for the First Circuit · 1998

12 more not listed; retrieve them via the Exa API.

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