Coors v. Commissioner
United States Tax Court
Held: 1. Where the Commissioner did not concede the correctness of the company's accounting treatment of its self-constructed assets in abandoning capitalization adjustments in litigation involving the company for prior years, the doctrines of res judicata and collateral estoppel do not apply to the present litigation. 2. The company's method of accounting for its self-constructed assets does not clearly reflect its income on an annual basis and is erroneous for Federal…
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Held: 1. Where the Commissioner did not concede the correctness of the company's accounting treatment of its self-constructed assets in abandoning capitalization adjustments in litigation involving the company for prior years, the doctrines of res judicata and collateral estoppel do not apply to the present litigation. 2. The company's method of accounting for its self-constructed assets does not clearly reflect its income on an annual basis and is erroneous for Federal income tax purposes. Costs of its self-constructed assets represent capital expenditures under sec. 263, I.R.C. 1954. 3. The…
1Opinion of the Court
William K. Coors and Phyllis E. Coors, et al.,1 Petitioners v. Commissioner of Internal Revenue, Respondent
Coors v. Commissioner
Docket Nos. 2837-69, 2839-69, 2840-69
United States Tax Court
60 T.C. 368; 1973 U.S. Tax Ct. LEXIS 109;
June 12, 1973, Filed
Decisions will be entered under Rule 50.
Held: 1. Where the Commissioner did not concede the correctness of the company's accounting treatment of its self-constructed assets in abandoning capitalization adjustments in litigation involving the company for prior years, the doctrines of res judicata and collateral estoppel do not apply to the present…
2Cases cited70 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Cromwell v. County of SacSupreme Court of the United States · 1877
- Lawlor v. National Screen Service Corp.Supreme Court of the United States · 1955
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Angel v. BullingtonSupreme Court of the United States · 1947
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