Chickasha Cotton Oil Co. v. Commissioner
United States Board of Tax Appeals
1. Held that the petitioner has not established error on the part of the respondent in including in income gains realized from insurance on two cotton gins destroyed by fire, the evidence being insufficient to show that petitioner complied with the requirements of section 234(a)(14) of the Revenue Act of 1921 in acquiring one gin by foreclosure and in constructing another. 2. Deductions allowed for the cost of replacing parts of cotton gins, the replacements being made after…
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1. Held that the petitioner has not established error on the part of the respondent in including in income gains realized from insurance on two cotton gins destroyed by fire, the evidence being insufficient to show that petitioner complied with the requirements of section 234(a)(14) of the Revenue Act of 1921 in acquiring one gin by foreclosure and in constructing another. 2. Deductions allowed for the cost of replacing parts of cotton gins, the replacements being made after petitioner had sold the gins.
1Opinion of the Court
*1147OPINION.
Aeundell:
Section 284 (a) (14) of the Bevenue Act of 1921 provides that “If property is compulsorily or involuntarily converted into cash or its equivalent as a result of (A) its destruction in whole or in part, * * * and if the taxpayer proceeds forthwith in good faith, under regulations prescribed by the Commissioner with the approval of the Secretary, to expend the proceeds of such conversion in the acquisition of other property of a character similar or related in service or use to the property so converted, * * * or in the establishment of a replacement fund, then there shall be…
2Cases cited1 opinion
- Dickerman v. Northern Trust Co.Supreme Court of the United States · 1900
3Cited by10 opinions
- Descartes v. Tribunal de Contribuciones de Puerto RicoSupreme Court of Puerto Rico · 1953
- FRISCHKORN DEV. CO. v. COMMISSIONERUnited States Board of Tax Appeals · 1934
- Walling v. CommissionerUnited States Tax Court · 1965
- Chickasha Cotton Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Estate of Walling v. CommissionerUnited States Tax Court · 1965
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