Seaboard C. L. R. Co. v. Commissioner
United States Tax Court
Petitioner is the successor by merger to ACL, an interstate railroad which used the retirement-replacement-betterment method of accounting for its track structure during the years at issue. Held, during the years at issue: 1. In applying the retirement-replacement-betterment method of accounting, the deductions claimed by ACL for rail replaced or retired along its lines must be reduced by the fair market value of the rail which is recovered for reuse, i.e., relay rail.
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Petitioner is the successor by merger to ACL, an interstate railroad which used the retirement-replacement-betterment method of accounting for its track structure during the years at issue. Held, during the years at issue: 1. In applying the retirement-replacement-betterment method of accounting, the deductions claimed by ACL for rail replaced or retired along its lines must be reduced by the fair market value of the rail which is recovered for reuse, i.e., relay rail. Louisville & Nashville Railroad Co. v. Commissioner, 66 T.C. 962 (1976), on appeal (6th Cir., June 2, 1978), followed. 2. The…
1Opinion of the Court
Seaboard Coast Line Railroad Company, Successor by Merger to Atlantic Coast Line Railroad Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Seaboard C. L. R. Co. v. Commissioner
Docket No. 3777-71
United States Tax Court
72 T.C. 855; 1979 U.S. Tax Ct. LEXIS 74;
August 22, 1979, Filed
Decision will be entered under Rule 155.
Petitioner is the successor by merger to ACL, an interstate railroad which used the retirement-replacement-betterment method of accounting for its track structure during the years at issue. Held, during the years at issue:
1. In applying the…
2Cases cited26 opinions
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Dixon v. United StatesSupreme Court of the United States · 1965
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Messing v. CommissionerUnited States Tax Court · 1967
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