Leamington Hotel Co. v. Commissioner
United States Board of Tax Appeals
1. Minnesota property taxes which become a liability on May 1 are not deductible by the petitioner, although paid by it, where the property taxed was not acquired until June. The amount paid by the petitioner represented taxes of a prior owner and constituted an additional cost of the property to petitioner. 2. Petitioner accrued its estimated liability for water service as an expense for the taxable year and deducted the amount thereof in computing its net taxable income.
Read the full summary
1. Minnesota property taxes which become a liability on May 1 are not deductible by the petitioner, although paid by it, where the property taxed was not acquired until June. The amount paid by the petitioner represented taxes of a prior owner and constituted an additional cost of the property to petitioner. 2. Petitioner accrued its estimated liability for water service as an expense for the taxable year and deducted the amount thereof in computing its net taxable income. The charge was paid in the following year in an amount less than that estimated. Held, that the amount actually paid…
1Opinion of the Court
OPINION.
Lansdon :
The respondent bas asserted a deficiency in income tax for 1927 in the amount of $4,030.66. Two issues are presented by the pleadings, namely, whether a taxpayer on the accrual basis may deduct the amount of certain property taxes in 1927 where the property was acquired on June 11, 1927, and what amount, if any, may be deducted as accrued charges for water service in 1927 where payment was not made until 1928. All of the facts are stipulated.
The petitioner is a Delaware corporation, organized on June 4,1927, with its principal office in Minneapolis, Minnesota. On June 11,…
2Cases cited3 opinions
- County of Martin v. DrakeSupreme Court of Minnesota · 1889
- State v. Northwestern Telephone Exchange Co.Supreme Court of Minnesota · 1900
- State v. BellinSupreme Court of Minnesota · 1900
3Cited by15 opinions
- Merchants Bank Bldg. Co. v. HelveringCourt of Appeals for the Eighth Circuit · 1936
- Lifson v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1938
- Missouri State Life Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1933
- Commissioner of Internal Revenue v. Rust's EstateCourt of Appeals for the Fourth Circuit · 1940
- Texas Coca-Cola Bottling Co. v. CommissionerUnited States Board of Tax Appeals · 1934
10 more not listed; retrieve them via the Exa API.