Legal Opinion

Cotton v. Commissioner

United States Board of Tax Appeals

Decided April 15, 1932No. Docket Nos. 45005, 51393PublishedCited by 7 opinions

1. Held, that the evidence fails to support a claim for accelerated depreciation of hotel property owned by petitioner in the taxable years. 2. In the circumstances herein a mineral lease abandoned in 1926 resulted in loss, if any, in that year.

1Opinion of the Court

*1160OPINION.

Lansdon:

The petitioner contends that changed conditions have accelerated obsolescence and shortened the useful life of her hotel property by one-third. She therefore claims the right to depreciated deductions on such account from net income in each of the taxable years at the rate of 3 per cent on the cost thereof. No evidence has been introduced to show that conditions have permanently changed for the worse in respect to the petitioner’s property since it was opened up as a hotel in 1913. That it has not greatly suffered from destructive competition is indicated by the fact that its…

2Cases cited7 opinions

  1. Grubb v. McAfeeTexas Supreme Court · 1919
  2. Aye v. Philadelphia Co.Supreme Court of Pennsylvania · 1899
  3. Buffalo Zinc & Copper Co. v. CrumpSupreme Court of Arkansas · 1902
  4. Bay State Petroleum Co. v. Penn Lubricating Co.Court of Appeals of Kentucky · 1905
  5. Brown v. Wilmore Coal Co.Court of Appeals for the Third Circuit · 1907

2 more not listed; retrieve them via the Exa API.

3Cited by7 opinions

  1. Cozzi v. CommissionerUnited States Tax Court · 1987
  2. In re ReedUnited States Bankruptcy Court, E.D. Tennessee · 2013
  3. Swanson v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Cotton v. CommissionerUnited States Board of Tax Appeals · 1932
  5. Cozzi v. CommissionerUnited States Tax Court · 1987

2 more not listed; retrieve them via the Exa API.

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