Legal Opinion

Ambrose v. Commissioner

United States Tax Court

Decided June 30, 1952No. Docket No. 29340Published

Section 124 (d) (1), (4) -- Amortization of Emergency Facility. -- Petitioner owned an emergency facility. He elected to take amortization deductions under sections 23 (t) and 124 (a), I. R. C., on the basis of the 60-month amortization period allowed. He owned the property from January 1943, until June 7, 1945, when it was taken under condemnation proceedings by the United States Government.

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Section 124 (d) (1), (4) -- Amortization of Emergency Facility. -- Petitioner owned an emergency facility. He elected to take amortization deductions under sections 23 (t) and 124 (a), I. R. C., on the basis of the 60-month amortization period allowed. He owned the property from January 1943, until June 7, 1945, when it was taken under condemnation proceedings by the United States Government. He made the election under sections 124 (d) (1) and (4) to retroactively recompute amortization deductions on the basis of a 32 month amortization period ending September 30, 1945, the end of the…

1Opinion of the Court

Frank J. Ambrose, Petitioner, v. Commissioner of Internal Revenue, Respondent

Ambrose v. Commissioner

Docket No. 29340

United States Tax Court

18 T.C. 690; 1952 U.S. Tax Ct. LEXIS 148;

June 30, 1952, Promulgated

Decision will be entered under Rule 50.

Section 124 (d) (1), (4) -- Amortization of Emergency Facility. -- Petitioner owned an emergency facility. He elected to take amortization deductions under sections 23 (t) and 124 (a), I. R. C., on the basis of the 60-month amortization period allowed. He owned the property from January 1943, until June 7, 1945, when it was taken under condemnation…

Also in this document: Dissent · Opper; Dissent · Raum.

2Cases cited6 opinions

  1. United States v. LudeySupreme Court of the United States · 1927
  2. Estate of Edmonds v. CommissionerUnited States Tax Court · 1951
  3. American Coast Line v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1947
  4. Ken-Rad Tube & Lamp Corp. v. CommissionerUnited States Tax Court · 1948
  5. Ken-Rad Tube & Lamp Corp. v. Commissioner of Internal Revenue. Ken-Rad Transmitting Tube Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1950

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