Cramp Shipbuilding Co. v. Commissioner
United States Tax Court
Closing Agreement -- Section 3760, I. R. C. -- Binding Effect. -- The taxpayer is entitled to accelerated amortization of emergency plant facilities in accordance with an election under section 124, I. R. C., where the taxpayer and the Commissioner entered into a closing agreement under section 3760 providing that the taxpayer could take amortization deductions under section 124, and where the parties stipulated facts satisfying the requirements of section 124 and showing…
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Closing Agreement -- Section 3760, I. R. C. -- Binding Effect. -- The taxpayer is entitled to accelerated amortization of emergency plant facilities in accordance with an election under section 124, I. R. C., where the taxpayer and the Commissioner entered into a closing agreement under section 3760 providing that the taxpayer could take amortization deductions under section 124, and where the parties stipulated facts satisfying the requirements of section 124 and showing the amount of deductions to which the taxpayer is entitled.
1Opinion of the Court
OPINION.
Murdoch, Judge:
The Commissioner determined deficiencies in the income and excess profits tax of the petitioner as follows:
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The only issue for decision at this time, there having been a severance of other issues, is whether the petitioner, Cramp Shipbuilding Co., hereinafter .referred to as Cramp, is entitled to deductions for the years 1943, 1944, and 1945 for amortization of its emergency plant facilities on the basis of an accelerated period of 33 months, instead of on the basis of 60 months as allowed by the Commissioner in determining the deficiency. The truth of all…
2Cases cited1 opinion
- Phillips v. CommissionerUnited States Tax Court · 1947
3Cited by13 opinions
- Zaentz v. CommissionerUnited States Tax Court · 1988
- Avco Mfg. Corp. v. CommissionerUnited States Tax Court · 1956
- Estate of Showers v. CommissionerUnited States Tax Court · 1950
- Estate of Johnson v. CommissionerUnited States Tax Court · 1987
- Lake Erie Engineering Corp. v. McGowanDistrict Court, W.D. New York · 1957
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