Cotton States Fertilizer Co. v. Commissioner
United States Tax Court
During the taxable year ended June 30, 1952, two of petitioner's plants were destroyed by fire. Petitioner carried fire insurance but in order to present its claims for insurance it employed a firm of architects to recreate plans and specifications and a contractor to estimate the replacement cost of the destroyed plants. As a result of such claims petitioner recovered insurance proceeds exceeding the adjusted basis of the plants.
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During the taxable year ended June 30, 1952, two of petitioner's plants were destroyed by fire. Petitioner carried fire insurance but in order to present its claims for insurance it employed a firm of architects to recreate plans and specifications and a contractor to estimate the replacement cost of the destroyed plants. As a result of such claims petitioner recovered insurance proceeds exceeding the adjusted basis of the plants. It placed the proceeds in a "replacement" account and used such proceeds in replacing the destroyed property, the cost of which exceeded the proceeds, and in…
1Opinion of the Court
OPINION.
Arundell, Judge:
Respondent determined a deficiency in income tax for the taxable year ended June 30, 1952, in the amount of $2,932.54. Only that portion of the deficiency attributable to the disallowance as expense deductions of certain professional fees paid to a firm of architects and a contractor in the total amount of $3,452 is contested.
The parties have submitted this proceeding upon a stipulation of facts pursuant to Buie 30 of the Court’s Eules of Practice. A summary of this stipulation is set forth, below.
Petitioner is a corporation organized and existing under the laws of the…
2Cases cited3 opinions
- Ticket Office Equipment Co. v. CommissionerUnited States Tax Court · 1953
- National Engraving Co. v. CommissionerUnited States Tax Court · 1944
- Donald B. Jones & Mercy P. Jones v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956
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- Nelson v. CommissionerUnited States Tax Court · 1998
- McDonald v. CommissionerUnited States Tax Court · 1961
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