Legal Opinion
Amfac, Inc. v. Commissioner of Internal Revenue
Court of Appeals for the Ninth Circuit
Decided August 21, 1980No. 78-2918PublishedCited by 3 opinions
1Opinion of the Court
RUSSELL E. SMITH, District Judge:
The sole question in this case is whether certain expenditures made by Puna Sugar Co., Ltd. (Puna), a subsidiary of the petitioner, Amfac, Inc., are deductible under Section 175(a) of the Internal Revenue Code (26 U.S.C. § 175(a)). The Tax Court held an evidentiary hearing, made findings of fact, and concluded that the expenses were not deductible. We affirm.
The record shows that Puna has been growing sugar cane on the Island of Hawaii since about 1900. In 1967 it made improvements in its sugar mill which substantially increased its capacity. In 1968, to use…
2Cases cited8 opinions
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- James E. Austin and Elizabeth G. Austin v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1962
- George T. McLean and Amelia G. McLean v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1961
- A. Duda & Sons, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1977
- Behring v. CommissionerUnited States Tax Court · 1959
3 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Kelly B. Niles, by and Through His Co-Conservators, David F. Niles and Joan A. MacMahon v. United StatesCourt of Appeals for the Ninth Circuit · 1983
- Sherwood v. CommissionerUnited States Tax Court · 1988
- Tharp v. CommissionerUnited States Tax Court · 1989