Walling v. Commissioner
United States Tax Court
The owners of two vessels agreed to transfer them to the X corporation. As required by the agreement and as an incident to the transfer the owners made expenditures for needed repairs to the vessels. Held, such expenditures were capital in nature and were not deductible as ordinary and necessary expenses.
1Opinion of the Court
Estate of Ritner K. Walling, Deceased, Margaret C. Walling, Ritner E. Walling and J. Wesley McWilliams, Executors, and Margaret C. Walling, Surviving Wife, Petitioners, v. Commissioner of Internal Revenue, Respondent
Walling v. Commissioner
Docket No. 4274-62
United States Tax Court
45 T.C. 111; 1965 U.S. Tax Ct. LEXIS 22;
October 25, 1965, Filed
Decision will be entered for the respondent.
The owners of two vessels agreed to transfer them to the X corporation. As required by the agreement and as an incident to the transfer the owners made expenditures for needed repairs to the vessels. Held, such…
2Cases cited3 opinions
- Bloomfield Steamship Co. v. CommissionerUnited States Tax Court · 1959
- Chickasha Cotton Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1930
- Walling v. CommissionerUnited States Tax Court · 1965