Woodside Cotton Mills Co. v. Commissioner
United States Board of Tax Appeals
1. The fact that exhaustion of machinery is accelerated under unusual conditions of operation is not sufficient evidence of the rate at which such exhaustion should be measured. 2. The rate of exhaustion must be based on facts in evidence and is not proven by opinions of witnesses whose judgment is not shown to be authoritative or convincing. 3. Expenditures for paving streets of petitioner's mill village are capital, and the fact that they are occasioned by the necessity to…
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1. The fact that exhaustion of machinery is accelerated under unusual conditions of operation is not sufficient evidence of the rate at which such exhaustion should be measured. 2. The rate of exhaustion must be based on facts in evidence and is not proven by opinions of witnesses whose judgment is not shown to be authoritative or convincing. 3. Expenditures for paving streets of petitioner's mill village are capital, and the fact that they are occasioned by the necessity to attract competitive labor does not make them deductible as ordinary and necessary expenses. 4. The fact that such…
1Opinion of the Court
*268OPINION.
SteRnhagbn :
The several issues presented by the petitioner have already been set forth and will be considered in the order in which they have been presented.
The petitioner claims that for the years 1918 and 1919 the exhaustion of its machinery was so Seriously increased by inefficient labor and other conditions growing out of the war that instead of the usual rate of 5 per cent, ivhich both parties agree is applicable under usual conditions, its deduction for depreciation should be at the rate of 10 per cent, or double the usual rate. The Commissioner in determining the deficiency…
2Cases cited1 opinion
- The ConquerorSupreme Court of the United States · 1897
3Cited by12 opinions
- Central Bank Co. v. CommissionerUnited States Tax Court · 1963
- Woodside Mills v. United StatesCourt of Appeals for the Fourth Circuit · 1958
- Wilson & Co. v. United StatesUnited States Court of Claims · 1936
- E. W. Edwards & Son v. ClarkeDistrict Court, N.D. New York · 1939
- Advance Mach. Exch. v. CommissionerUnited States Tax Court · 1949
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