Legal Opinion

Southern Pacific Transp. Co. v. Commissioner

United States Tax Court

Decided December 31, 1980No. Docket No. 3493-69Published

CONTENTSPageHeadnote499Opinion (Introduction)505General Findings of Fact506I.Issue (i): Rapid Amortization of Freight Cars515Findings of Fact515Opinion534II.Issues (hh) and (9): Recovery Upon Mergerof Previously Deducted Amounts 548Findings of Fact549Opinion557III.Issue (kk): Deduction of Timber Expenses567Findings of Fact567Opinion577IV.Issues (w) and (x): Deductions InvolvingHouston Depot 586Findings of Fact587Opinion594V.Issue (rr): Deductions Incident to…

Read the full summary

CONTENTSPageHeadnote499Opinion (Introduction)505General Findings of Fact506I.Issue (i): Rapid Amortization of Freight Cars515Findings of Fact515Opinion534II.Issues (hh) and (9): Recovery Upon Mergerof Previously Deducted Amounts 548Findings of Fact549Opinion557III.Issue (kk): Deduction of Timber Expenses567Findings of Fact567Opinion577IV.Issues (w) and (x): Deductions InvolvingHouston Depot 586Findings of Fact587Opinion594V.Issue (rr): Deductions Incident to RelocationProjects 605Findings of Fact605Opinion612VI.Issue (bbb): Deduction of Estimated PayrollTaxes on Earned Vacation Pay…

1Opinion of the Court

Southern Pacific Transportation Company, Petitioner v. Commissioner of Internal Revenue, Respondent

Southern Pacific Transp. Co. v. Commissioner

Docket No. 3493-69

United States Tax Court

75 T.C. 497; 1980 U.S. Tax Ct. LEXIS 1;

December 31, 1980, Filed

Decision will be entered under Rule 155.

CONTENTS

Page

Headnote

499

Opinion (Introduction)

505

General Findings of Fact

506

I

Issue (i): Rapid Amortization of Freight Cars

515

Findings of Fact

515

Opinion

534

II

Issues (hh) and (9): Recovery Upon Merger

of Previously Deducted Amounts

548

Findings of Fact

549

Opinion

557

III

Issue (kk): Deduction of Timber Expenses

567

Findings…

2Cases cited308 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Simon v. Eastern Kentucky Welfare Rights OrganizationSupreme Court of the United States · 1976
  3. Udall v. TallmanSupreme Court of the United States · 1965
  4. New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
  5. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930

303 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API