Legal Opinion

Gray v. Commissioner

United States Tax Court

Decided January 31, 1951No. Docket No. 21337Published

Petitioner is held to be not entitled to deductions for amortization of war facilities under section 124, Internal Revenue Code, where no application for certificate of necessity was timely filed and no certificate of necessity was issued.

1Opinion of the Court

Frank A. Gray, Petitioner, v. Commissioner of Internal Revenue, Respondent

Gray v. Commissioner

Docket No. 21337

United States Tax Court

16 T.C. 262; 1951 U.S. Tax Ct. LEXIS 288;

January 31, 1951, Promulgated

Decision will be entered for the respondent.

Petitioner is held to be not entitled to deductions for amortization of war facilities under section 124, Internal Revenue Code, where no application for certificate of necessity was timely filed and no certificate of necessity was issued.

Emmett E. Eagan, Esq., for the petitioner.

Cyrus A. Neuman, Esq., for the respondent.

Leech, Judge.

LEECH

Respondent…

2Cases cited3 opinions

  1. United States v. LombardoSupreme Court of the United States · 1916
  2. Gray v. CommissionerUnited States Tax Court · 1951
  3. American Twist Drill Co. v. CommissionerUnited States Tax Court · 1948

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