Denver & R. G. W. R. Co. v. Commissioner
United States Tax Court
1. Deductions -- Losses -- Basis of Railroad Right-of-way Properties Paid for by Shippers. -- The cost of sidings built on petitioner's right-of-way at the expense of shippers, which expense was not reimbursed to the shippers, is not includible in the petitioner's basis for determining loss on retirement of the sidings.
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1. Deductions -- Losses -- Basis of Railroad Right-of-way Properties Paid for by Shippers. -- The cost of sidings built on petitioner's right-of-way at the expense of shippers, which expense was not reimbursed to the shippers, is not includible in the petitioner's basis for determining loss on retirement of the sidings. Detroit Edison Co. v. Commissioner, 319 U.S. 98, followed. 2. Deductions -- Property Taxes. -- Moffat Tunnel Improvement District levy deductible only to extent allocable to maintenance and interest charges as determined by the Commissioner. Western Products Co., 28 T.C. 1196,…
1Opinion of the Court
Murdock, Judge:
The Commissioner determined deficiences in the petitioner’s income tax of $44,278.54 for 1951, $104,974.30 for 1952, and $242,259.36 for 1953.
GENERAL FINDINGS OF FACT.
The petitioner filed its income tax returns for the calendar years 1951, 1952, and 1953 with the director of internal revenue at Denver, Colorado. It used an accrual method of accounting. The petitioner, a corporation, is a common carrier by rail operating principally in the States of Colorado and Utah. It was organized in 1908 by the consolidation of the Denver & Rio Grande Railroad Company and the Rio Grande…
2Cases cited32 opinions
- United States v. AndersonSupreme Court of the United States · 1926
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Dixie Pine Products Co. v. CommissionerSupreme Court of the United States · 1944
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
- Helvering v. Union Pacific RailroadSupreme Court of the United States · 1934
27 more not listed; retrieve them via the Exa API.
3Cited by55 opinions
- Denver & Rio Grande Western Railroad Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1960
- Jefferson v. CommissionerUnited States Tax Court · 1968
- Andrew v. CommissionerUnited States Tax Court · 1970
- Denver & Rio Grande Western Railroad v. United StatesUnited States Court of Claims · 1974
- James A. Messer Co. v. CommissionerUnited States Tax Court · 1972
50 more not listed; retrieve them via the Exa API.