Monsanto Co. v. Commissioner
United States Tax Court
Petitioner operates integrated mining-manufacturing plants for the production of elemental phosphorous. To reduce costs, petitioner uses carbon in both mining and nonmining activities. Held: The costs of carbon are to be allocated between petitioner's mining and nonmining activities. The allocation is to be based on the substituted fuel method, and the substitute fuel to be used in the allocation is coal.
1Opinion of the Court
Monsanto Company and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Monsanto Co. v. Commissioner
Docket No. 22597-81
United States Tax Court
86 T.C. 1232; 1986 U.S. Tax Ct. LEXIS 96; 86 T.C. No. 72;
June 18, 1986, Filed
Decision will be entered under Rule 155.
Petitioner operates integrated mining-manufacturing plants for the production of elemental phosphorous. To reduce costs, petitioner uses carbon in both mining and nonmining activities. Held: The costs of carbon are to be allocated between petitioner's mining and nonmining activities. The allocation is to be based on…
2Cases cited7 opinions
- Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
- Standard Lime and Cement Company (Formerly Known as the Standard Lime and Stone Company) v. The United StatesUnited States Court of Claims · 1964
- Virginia Greenstone Company, Incorporated v. United StatesCourt of Appeals for the Fourth Circuit · 1962
- United States v. Light Aggregates, Inc.Court of Appeals for the Eighth Circuit · 1965
- Solite Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1967
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