Fall River Gas Appliance Co. v. Commissioner
United States Tax Court
1. Held, installation expenses of leased gas appliances must be capitalized. Useful life of such installations redetermined. 2. Held, installation, selling, and miscellaneous expenses incurred by subsidiary corporation in connection with sales of gas appliances but paid by parent gas company may be deducted by latter where directly related to its business of selling gas.
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1. Held, installation expenses of leased gas appliances must be capitalized. Useful life of such installations redetermined. 2. Held, installation, selling, and miscellaneous expenses incurred by subsidiary corporation in connection with sales of gas appliances but paid by parent gas company may be deducted by latter where directly related to its business of selling gas. Held, further, installation expenses of the subsidiary in connection with gas appliances leased by it may not be deducted by the parent.
1Opinion of the Court
OPINION
Raum, Judge:
1. Appliance company's 1957 cost of installing leased applimees. — In 1957 the appliance company incurred various costs in connection with its sales and leases of gas appliances. As to sales, it had “selling expenses” of $8,847.50, “miscellaneous expenses” of $9,132.36, and “installation expenses” of $57,677.55. The Commissioner allowed the deductions of all of these expenses, and they aro not involved herein. The appliance company, however, claimed a further deduction in the amount of $21,035.76 as “installation” expenses in respect of its leased gas appliances, which the…
2Cases cited9 opinions
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Columbian Rope Co. v. CommissionerUnited States Tax Court · 1964
- Houston Natural Gas Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1937
- Kauai Terminal, Ltd. v. CommissionerUnited States Board of Tax Appeals · 1937
- Fishing Tackle Products Co. v. CommissionerUnited States Tax Court · 1957
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3Cited by27 opinions
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- Fall River Gas Appliance Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1965
- USFreightways Corp. v. CommissionerUnited States Tax Court · 1999
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