Pasadena City Lines, Inc. v. Commissioner (A)
United States Tax Court
Petitioner was granted a 10-year franchise to operate a motor coach transportation system in the city of Pasadena, California. Pursuant to the terms of its franchise, petitioner was required to purchase the franchises held by the corporation then operating a motor coach and rail transportation system in the city, and also to purchase and remove the overhead rail facilities which would no longer be used.
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Petitioner was granted a 10-year franchise to operate a motor coach transportation system in the city of Pasadena, California. Pursuant to the terms of its franchise, petitioner was required to purchase the franchises held by the corporation then operating a motor coach and rail transportation system in the city, and also to purchase and remove the overhead rail facilities which would no longer be used. Petitioner incurred certain legal and other expenses incident to the acquisition of its franchise and the consummation of the purchase transaction with the previous operator of the…
1Opinion of the Court
OPINION.
Rice, Judge:
This proceeding involves deficiencies in income and excess profits taxes determined against Pasadena City Lines, Inc. (hereinafter referred to as petitioner), as follows:
Year Tam Deficiency
1944_Excess profits_$8, 647. 64
1945_Excess profits_ 27,123.81
1946_Income_ 5, 091. 84
The issues to be decided are: (1) Whether the cost to petitioner of acquiring a franchise to operate a motor coach transportation system was $134,177.37; and (2) whether the cost of such franchise may he depreciated over a 10-year period.
Petitioner claims, in its petition, an overpayment of excess profits…
2Cases cited7 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- City of Omaha v. Omaha Water Co.Supreme Court of the United States · 1910
- Nachman v. Commissioner of Internal Revenue. Tobias v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- Nachman v. CommissionerUnited States Tax Court · 1949
- Central Bank Block Ass'n v. Commissioner of Int. Rev.Court of Appeals for the Fifth Circuit · 1932
2 more not listed; retrieve them via the Exa API.
3Cited by30 opinions
- Dustin v. CommissionerUnited States Tax Court · 1969
- Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
- Radio Station WBIR, Inc. v. CommissionerUnited States Tax Court · 1959
- Commissioner of Internal Revenue v. Indiana Broadcasting CorporationCourt of Appeals for the Seventh Circuit · 1965
- Toledo TV Cable Co. v. CommissionerUnited States Tax Court · 1971
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