Squirt Co. v. Commissioner
United States Tax Court
S Co. suffered a casualty to certain citrus tree land. Held, the amount deductible as a casualty loss under sec. 165(a), I.R.C. 1954, determined to be equal to the cost of restoring the land to its precasualty condition and not the net decrease in fair market value of the land.
1Opinion of the Court
TietjeNS, Judge:
The Commissioner determined a deficiency in petitioner’s income tax for the taxable year ending December 31, 1962, in the amount of $48,863.10.
Due to the concessions that have been made, the only issue is whether petitioner suffered a casualty loss to its land and, if so, the amount deductible under section 165, I.R.C. 1954.1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation and exhibits attached thereto are incorporated herein by this reference.
Petitioner, the Squirt Co., was organized as a corporation in 1946, from a prior-existing…
2Cases cited7 opinions
- Hort v. CommissionerSupreme Court of the United States · 1941
- Peterson v. CommissionerUnited States Tax Court · 1958
- A. Giurlani & Bro. v. Com'r of Int. Rev.Court of Appeals for the Ninth Circuit · 1941
- Pulvers v. CommissionerUnited States Tax Court · 1967
- Knapp v. CommissionerUnited States Tax Court · 1955
2 more not listed; retrieve them via the Exa API.
3Cited by28 opinions
- Lamphere v. CommissionerUnited States Tax Court · 1978
- The Squirt Company v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
- Keith v. CommissionerUnited States Tax Court · 1969
- Kamanski v. CommissionerUnited States Tax Court · 1970
- Corby v. CommissionerUnited States Tax Court · 1980
23 more not listed; retrieve them via the Exa API.