Legal Opinion

Cotton Concentration Co. v. Commissioner

United States Board of Tax Appeals

Decided June 21, 1926No. Docket No. 4625Published

1. Where expenditures were made, partly for a new roof and partly for an old roof, held, that only the amount which can be identified as having been expended for repairs may be deducted. 2. In determining gain or loss on conversion of capital assets, due allowance must be made for depreciation. 3. Where the taxpayer owned two buildings, one of which was entirely destroyed and the other partly destroyed by fire, and only one was reconstructed, of larger size and at greater…

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1. Where expenditures were made, partly for a new roof and partly for an old roof, held, that only the amount which can be identified as having been expended for repairs may be deducted. 2. In determining gain or loss on conversion of capital assets, due allowance must be made for depreciation. 3. Where the taxpayer owned two buildings, one of which was entirely destroyed and the other partly destroyed by fire, and only one was reconstructed, of larger size and at greater cost than the amount of insurance received to cover damage to both, held, that any gain realized from the insurance is…

1Opinion of the Court

APPEAL OF COTTON CONCENTRATION CO.

Cotton Concentration Co. v. Commissioner

Docket No. 4625.

United States Board of Tax Appeals

4 B.T.A. 121; 1926 BTA LEXIS 2357;

June 21, 1926, Decided Submitted December 15, 1925.

1. Where expenditures were made, partly for a new roof and partly for an old roof, held, that only the amount which can be identified as having been expended for repairs may be deducted.

2. In determining gain or loss on conversion of capital assets, due allowance must be made for depreciation.

3. Where the taxpayer owned two buildings, one of which was entirely destroyed and the other…

2Cases cited6 opinions

  1. Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
  2. Even Realty Co. v. CommissionerUnited States Board of Tax Appeals · 1925
  3. Simmons & Hammond Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1925
  4. Cotton Concentration Co. v. CommissionerUnited States Board of Tax Appeals · 1926
  5. Piedmont-Mt. Airy Guano Co. v. CommissionerUnited States Board of Tax Appeals · 1926

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