Evergreen-Washelli Memorial Park Co. v. Commissioner
United States Tax Court
On its 1963 and 1964 income tax returns, petitioner deducted certain expenditures which it had incurred in replacing a pipeline in one of the cemeteries it operated. The Commissioner disallowed these deductions and determined that the pipeline replacement costs were capital expenditures under sec. 263, I.R.C. 1954, which should be recovered through periodic depreciation deductions. Held, the expenditures incurred by petitioner should be added to its improved-land account.
1Opinion of the Court
Fat, Judge:
Respondent determined deficiencies in the Federal income tax of petitioner as follows:
Tear Amount
1963 _$7,438. 54
1964 _ 1,569.00
After certain concessions the only issue remaining for determination is whether the Commissioner properly capitalized certain expenditures incurred by petitioner in 1963 and 1964.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulation of facts, together with the exhibits attached thereto, is incorporated herein by this reference.
Evergreen-Washelli Memorial Park Co. (hereinafter referred to as petitioner) is a Washington corporation…
2Cases cited5 opinions
- Sherwood Memorial Gardens, Inc., (Tennessee) v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1965
- Sherwood Memorial Gardens, Inc. v. CommissionerUnited States Tax Court · 1964
- National Memorial Park v. Commissioner of Int. Rev.Court of Appeals for the Fourth Circuit · 1944
- Mount Vernon Gardens, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1962
- Mt. Vernon Gardens, Inc. v. CommissionerUnited States Tax Court · 1960
3Cited by1 opinion
- Evergreen-Washelli Memorial Park Co. v. CommissionerUnited States Tax Court · 1968