Van De Steeg v. Commissioner
United States Tax Court
Petitioners are dairy farmers who market their milk production in the Puget Sound area. Since 1951 the marketing of milk in that area has been regulated by the Puget Sound Federal Milk Marketing Order which was promulgated pursuant to, and derives its statutory authority from, the Agricultural Marketing Agreement Act of 1937, as amended in 1965. On several occasions during the years 1967 through 1970 petitioners purchased an intangible asset, commonly referred to as a "class…
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Petitioners are dairy farmers who market their milk production in the Puget Sound area. Since 1951 the marketing of milk in that area has been regulated by the Puget Sound Federal Milk Marketing Order which was promulgated pursuant to, and derives its statutory authority from, the Agricultural Marketing Agreement Act of 1937, as amended in 1965. On several occasions during the years 1967 through 1970 petitioners purchased an intangible asset, commonly referred to as a "class I milk base," which was used by them in their business. As a result of these purchases, petitioners claimed deductions…
1Opinion of the Court
Dawson, Judge:
In these consolidated cases the respondent determined deficiencies in petitioners’ Federal income taxes, as follows:
Taxable year 1967 _ 1968 _ 1969 _ 1970 - Deficiency $321.24 1,922. 93 3, 778. 09 2,968. 68
Some adjustments made by the respondent in his notices of deficiencies are not contested by petitioners. At issue is whether the class I milk base purchased by petitioners during the years 1961 through 1970 is a depreciable intangible asset under section 167, I.R.C. 1954, and section 1.167(a)-3, Income Tax Regs. More specifically, the answer turns upon whether the purchased…
2Cases cited14 opinions
- Merrill v. CommissionerUnited States Tax Court · 1963
- Nachman v. Commissioner of Internal Revenue. Tobias v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Nachman v. CommissionerUnited States Tax Court · 1949
- Kwtx Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1959
- KWTX Broadcasting Co. v. CommissionerUnited States Tax Court · 1959
9 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Lemmen v. CommissionerUnited States Tax Court · 1981
- Chronicle Publishing Co. v. CommissionerUnited States Tax Court · 1977
- Wenzel v. CommissionerUnited States Tax Court · 1991
- Chronicle Publishing Co. v. CommissionerUnited States Tax Court · 1977
- Gerrit Van De Steeg and Eileen Van De Steeg. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
3 more not listed; retrieve them via the Exa API.