Legal Opinion
Lomas Santa Fe, Inc. v. Commissioner
Court of Appeals for the Ninth Circuit
Decided November 1, 1982No. 81-7092PublishedCited by 6 opinions
1Opinion of the Court
TANG, Circuit Judge:
This is an appeal from a Tax Court judgment in favor of the Commissioner. The issue presented is whether a taxpayer may claim a depreciation deduction under T.R.C. § 1671 for the amortization of an estate for years in real property if the estate was created by the taxpayer splitting its fee simple interest into two parts and conveying the remainder to a wholly owned subsidiary. We conclude that this estate for years is not depreciable for tax purposes and affirm the Tax Court.
The facts are carefully detailed in the Tax Court opinion. See Lomas Santa Fe, Inc. v.…
2Cases cited11 opinions
- Commissioner v. National Alfalfa Dehydrating & Milling Co.Supreme Court of the United States · 1974
- Century Electric Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1951
- Bell v. Harrison. Bell v. United StatesCourt of Appeals for the Seventh Circuit · 1954
- Fry v. CommissionerUnited States Tax Court · 1958
- United States v. Georgia Railroad and Banking CompanyCourt of Appeals for the Fifth Circuit · 1965
6 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Chapman Glen Ltd. v. CommissionerUnited States Tax Court · 2013
- Roy C. Wilkin v. United StatesCourt of Appeals for the Ninth Circuit · 1987
- CGF Indus., Inc. v. CommissionerUnited States Tax Court · 1999
- Chapman Glen Limited v. CommissionerUnited States Tax Court · 2013
- Chapman v. CommissionerUnited States Tax Court · 1997
1 more not listed; retrieve them via the Exa API.