Cooper v. Commissioner
United States Tax Court
Held, improvements to subdivided real estate held for sale, which included construction of roads and the installation of curbs, gutters, waterlines, and storm sewers, do not constitute depreciable property within the meaning of section 167 of the 1954 Code.
1Opinion of the Court
OPINION.
Tietjrns, Judge:
This proceeding involves a deficiency in income tax for the taxable year 1954 in the amount of $526.61, and an addition thereto under section 294(d) (1) (B) of the 1939 Code in the amount of $140.67.
The only issue for decision is whether petitioners are entitled to a deduction for depreciation on improvements to subdivided real estate held for sale.
All of the facts were stipulated, are so found, and are incorporated herein by this reference.
During the taxable year 1954, petitioners, husband and wife, resided in Piketon, Ohio. They filed a joint Federal income tax…
2Cases cited4 opinions
- Camp Wolters Enterprises, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1956
- Commissioner of Internal Rev. v. Laguna Land & W. Co.Court of Appeals for the Ninth Circuit · 1941
- Wood v. CommissionerCourt of Appeals for the Fifth Circuit · 1957
- Nulex, Inc. v. CommissionerUnited States Tax Court · 1958
3Cited by10 opinions
- D. Loveman & Son Export Corp. v. CommissionerUnited States Tax Court · 1960
- Mount Vernon Gardens, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1962
- Derby Heights, Inc. v. CommissionerUnited States Tax Court · 1967
- Kenneth A. Murry and Helen J. Murry v. Commissioner of Internal Revenue, Lakeside Garden Developers, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979
- Friedman v. Comm'rUnited States Tax Court · 1977
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