Austin Co. v. Commissioner
United States Tax Court
Held, petitioner's 12-year useful life on depreciable equipment approved. Held, further, loan expenses have indeterminable useful life and therefore are not subject to amortization.
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Held, petitioner's 12-year useful life on depreciable equipment approved. Held, further, loan expenses have indeterminable useful life and therefore are not subject to amortization. Held, further, petitioner's expenses incurred in reimbursing a foreign subsidiary for foreign taxes it paid are not deductible under sec. 162, I.R.C. 1954. Held, further: Petitioner's stock and debt in a foreign subsidiary were worthless in its fiscal year ended June 30, 1971; accordingly, it is entitled to an ordinary loss under secs. 165(g) and 166(a)(2), I.R.C. 1954. Petitioner's worthless and deductible debt,…
1Opinion of the Court
The Austin Company, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Austin Co. v. Commissioner
Docket No. 1312-75
United States Tax Court
71 T.C. 955; 1979 U.S. Tax Ct. LEXIS 161;
March 5, 1979, Filed
Decision will be entered under Rule 155.
Held, petitioner's 12-year useful life on depreciable equipment approved. Held, further, loan expenses have indeterminable useful life and therefore are not subject to amortization. Held, further, petitioner's expenses incurred in reimbursing a foreign subsidiary for foreign taxes it paid are not deductible under sec. 162, I.R.C. 1954. Held,…
2Cases cited26 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Enoch v. CommissionerUnited States Tax Court · 1972
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