Richmond Dairy Lunch v. Commissioner
United States Board of Tax Appeals
Evidence of the capital value of leaseholds held to be insufficient to support a claim for a deduction of any amount from gross income based upon the exhaustion of such leaseholds. Such property rights as leaseholds and good will acquired by a corporation for stock can be included in invested capital only when the actual cash value of such properties at the time paid in for stock is definitely proven.
1Opinion of the Court
*877OPINION.
Trussell:
The taxpayer in its petition claimed deductions from gross income on account of exhaustion of leaseholds for both the *878.years 1919 and 1920 and a loss on an automobile for the year 1919. It also claimed that its capital account of good will should be included in invested capital at the value carried upon its books. In the presentation of its appeal the taxpayer furnished no evidence or argument concerning the alleged loss upon an automobile and relied wholly on the issues of depreciation on leaseholds and the inclusion of its good-will item in invested capital. Respecting the…
2Cited by3 opinions
- Albert Lea Packing Co. v. CommissionerUnited States Board of Tax Appeals · 1931
- H. S. Crocker Co. v. CommissionerUnited States Board of Tax Appeals · 1929
- Richmond Dairy Lunch v. CommissionerUnited States Board of Tax Appeals · 1925