Legal Opinion

Copperhead Coal Company, Inc. v. Commissioner of Internal Revenue

Court of Appeals for the Sixth Circuit

Decided December 4, 1959No. 13702_1PublishedCited by 47 opinions

1Opinion of the Court

McALLISTER, Chief Judge.

This is a petition for review of a decision of the Tax Court finding that the basis of petitioner’s depreciable assets was $650,000.00, instead of $1,000,000.-00, which petitioner contended it had paid for the tangible assets in question.

The government claimed, and the Tax Court found, that although, in the contract of purchase of the assets, the cost was set forth as $1,000,000.00, the actual value of the tangible assets was $650,-000.00, while the balance of the purchase price, in the amount of $350,000.-00, was for intangibles in the nature of good will, or value as…

2Cases cited2 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. Hamlin's Trust v. Commissioner of Internal Revenue. Nowel's Estate v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1954

3Cited by47 opinions

  1. VGS Corp. v. CommissionerUnited States Tax Court · 1977
  2. Buddy Schoellkopf Products, Inc. v. CommissionerUnited States Tax Court · 1975
  3. F. & D. Rentals, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1966
  4. F. & D. Rentals, Inc. v. CommissionerUnited States Tax Court · 1965
  5. The South Bay Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1965

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