Warner Mountains Lumber Co. v. Commissioner
United States Tax Court
1. Capitalization of Expenditures -- Properly Chargeable to Capital Account -- Sec. 113 (b) (1) (A). -- The propriety of capitalizing various expenditures determined.
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1. Capitalization of Expenditures -- Properly Chargeable to Capital Account -- Sec. 113 (b) (1) (A). -- The propriety of capitalizing various expenditures determined. Held, inter alia, that expenses of unsuccessful efforts to sell are not properly chargeable to capital account. 2. Capitalization of Expenditures -- Carrying Charges on Unproductive Property. -- Sec. 113 (b) (1) (A). -- The propriety of charging or of not charging certain items to capital as carrying charges on unproductive property determined. 3. Capital Assets. -- Standing timber held to be a capital asset.
1Opinion of the Court
OPINION.
Murdock, Judge:
All of the events upon which the present controversy rests occurred during the period from the creation of the syndicate up to the end of 1930, when the petitioner corporation took over all of the assets and assumed the liabilities of the syndicate in exchange for its stock. The petitioner states in its brief that the syndicate was an association taxable as' a corporation. Counsel for the respondent stated at the trial that the tax-free character of the transaction whereby the petitioner acquired the assets of the syndicate is not disputed and the petitioner is claiming…
2Cases cited3 opinions
- Spreckels v. CommissionerSupreme Court of the United States · 1942
- Jackson v. CommissionerUnited States Tax Court · 1947
- Pittsburgh & West Virginia Railway Co. v. CommissionerUnited States Tax Court · 1947
3Cited by17 opinions
- Crowell Land and Mineral Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Larsen v. CommissionerUnited States Tax Court · 1976
- Picker v. United StatesUnited States Court of Claims · 1967
- Thomas v. CommissionerUnited States Tax Court · 1957
- Thomas v. Commissioner (A)United States Tax Court · 1957
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