Evergreen-Washelli Memorial Park Co. v. Commissioner
United States Tax Court
On its 1963 and 1964 income tax returns, petitioner deducted certain expenditures which it had incurred in replacing a pipeline in one of the cemeteries it operated. The Commissioner disallowed these deductions and determined that the pipeline replacement costs were capital expenditures under sec. 263, I.R.C. 1954, which should be recovered through periodic depreciation deductions. Held, the expenditures incurred by petitioner should be added to its improved-land account.
1Opinion of the Court
Evergreen-Washelli Memorial Park Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Evergreen-Washelli Memorial Park Co. v. Commissioner
Docket No. 1867-67
United States Tax Court
51 T.C. 189; 1968 U.S. Tax Ct. LEXIS 37;
October 28, 1968, Filed
Decision will be entered under Rule 50.
On its 1963 and 1964 income tax returns, petitioner deducted certain expenditures which it had incurred in replacing a pipeline in one of the cemeteries it operated. The Commissioner disallowed these deductions and determined that the pipeline replacement costs were capital expenditures under sec. 263,…
2Cases cited6 opinions
- Sherwood Memorial Gardens, Inc., (Tennessee) v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1965
- Sherwood Memorial Gardens, Inc. v. CommissionerUnited States Tax Court · 1964
- National Memorial Park v. Commissioner of Int. Rev.Court of Appeals for the Fourth Circuit · 1944
- Mount Vernon Gardens, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1962
- Mt. Vernon Gardens, Inc. v. CommissionerUnited States Tax Court · 1960
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