Tonawanda Coke Corp. v. Commissioner
United States Tax Court
T purchased a coke-producing plant shortly after the plant had suffered a devastating fire. T made certain expenditures to remove debris from the fire and to repair the plant. The expenditures included the removal of ice and tar, the replacement of destroyed piping, and the shoring up of the plant's steel structure.
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T purchased a coke-producing plant shortly after the plant had suffered a devastating fire. T made certain expenditures to remove debris from the fire and to repair the plant. The expenditures included the removal of ice and tar, the replacement of destroyed piping, and the shoring up of the plant's steel structure. Respondent determined that the expenditures were for "demolition" for purposes of sec. 1.165-3(a)(1), Income Tax Regs., and that therefore the expenditures must be allocated to T's basis in the underlying land, rather than to its basis in the coke plant. Held, because no…
1Opinion of the Court
Tonawanda Coke Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Tonawanda Coke Corp. v. Commissioner
Docket No. 2894-88
United States Tax Court
95 T.C. 124; 1990 U.S. Tax Ct. LEXIS 74; 95 T.C. No. 10;
August 8, 1990, Filed
Decision will be entered under Rule 155.
T purchased a coke-producing plant shortly after the plant had suffered a devastating fire. T made certain expenditures to remove debris from the fire and to repair the plant. The expenditures included the removal of ice and tar, the replacement of destroyed piping, and the shoring up of the plant's steel structure.…
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- First Sav. & Loan Asso. v. CommissionerUnited States Tax Court · 1963
- Hotel Sulgrave, Inc. v. CommissionerUnited States Tax Court · 1954
- Gilman v. CommissionerUnited States Tax Court · 1979
- Charles L. Tidwell and Corinne S. Tidwell v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1962
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