Catron v. Commissioner
United States Tax Court
Petitioners Robert E. Catron and Eugene D. Catron are brothers who were engaged as partners in an apple-farming operation in Nebraska during 1962. That year they purchased and erected a prefabricated, steel, frameless Quonset-type structure to be used in connection with their apple business. Two-thirds of the Quonset facility which was 120 feet long and 40 feet wide, provided space for petitioners' selection, grading, and boxing operations.
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Petitioners Robert E. Catron and Eugene D. Catron are brothers who were engaged as partners in an apple-farming operation in Nebraska during 1962. That year they purchased and erected a prefabricated, steel, frameless Quonset-type structure to be used in connection with their apple business. Two-thirds of the Quonset facility which was 120 feet long and 40 feet wide, provided space for petitioners' selection, grading, and boxing operations. The other one-third of the facility was sealed off by a floor-to-ceiling wall in which there was a large refrigerator-type door opening into the working…
1Opinion of the Court
OPINION
Hoyt, Judge:
Respondent determined a deficiency against petitioners Robert E. and Maxine Catron, docket Ro. 2115-66, in the amount of $689.25 for the taxable year 1962. Respondent also determined a deficiency for the same year against petitioner Eugene D. Catron, docket JSTo. 8862-66, in the amount of $562.53.1 The cases have been consolidated for all purposes. The issue in both docket numbers is the same — i.e., whether an apple storage and packing facility erected by the petitioners, or portions thereof, qualify as “section 88 property” under the Internal Revenue Code of 1954.2
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2Cases cited4 opinions
- Evans v. CommissionerUnited States Tax Court · 1967
- Madison Newspapers, Inc. v. CommissionerUnited States Tax Court · 1967
- Schuyler Grain Co. v. CommissionerUnited States Tax Court · 1968
- J. E. Barron Plastics, Inc. v. CommissionerUnited States Tax Court · 1967
3Cited by65 opinions
- Coors v. CommissionerUnited States Tax Court · 1973
- Central Citrus Co. v. CommissionerUnited States Tax Court · 1972
- Consolidated Freightways, Inc. & Affiliates v. CommissionerUnited States Tax Court · 1980
- Brown-Forman Distillers Corp. v. United StatesUnited States Court of Claims · 1974
- Scott Paper Co. v. CommissionerUnited States Tax Court · 1980
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