Staples Coal Co. v. Commissioner
United States Board of Tax Appeals
Under the Revenue Act of 1921, held, the basis to be used for the fiscal year ended March 31, 1923, in the computation of depreciation on new vessels acquired and paid for in part with a replacement fund, established as a result of the involuntary conversion of certain other vessels, is the depreciated cost of the old vessels on the date of conversion, plus the cost of the new vessels over and above the amount of the replacement fund.
1Opinion of the Court
*821OPINION.
Seawall:
It is stipulated that in the instant case the base for depreciation was determined by the Commissioner in accordance with G. C. M. 2826, C. B. VII-1, p. 234, by taking, in the case of each vessel, the depreciated cost of the old vessel which it had replaced, plus the sum paid for the new vessel over and above the amount of the replacement fund. The contention of the petitioner is that the basis should be the entire sum paid for the new vessel, including the full amount of the replacement fund. The fiscal year involved ended March 31, 1923. The applicable law is found in the…
2Cases cited1 opinion
- United States v. LudeySupreme Court of the United States · 1927
3Cited by1 opinion
- Staples Coal Co. v. CommissionerUnited States Board of Tax Appeals · 1931