Spartanburg Terminal Co. v. Commissioner
United States Tax Court
Petitioner built a railroad tunnel and connecting tracks in downtown Spartanburg, S.C. Held: Petitioner failed to carry his burden to establish a useful life for its grading and tunnel bore. Consequently, no depreciation deductions are allowed with respect to these assets. Also, no investment credit is allowed for these assets. Held, further: Petitioner failed to carry his burden to establish a useful life for the easement obtained to construct and operate the tunnel.
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Petitioner built a railroad tunnel and connecting tracks in downtown Spartanburg, S.C. Held: Petitioner failed to carry his burden to establish a useful life for its grading and tunnel bore. Consequently, no depreciation deductions are allowed with respect to these assets. Also, no investment credit is allowed for these assets. Held, further: Petitioner failed to carry his burden to establish a useful life for the easement obtained to construct and operate the tunnel. No depreciation deductions are allowed for the cost of this easement. Held, further: Depreciation is allowed with respect to…
1Opinion of the Court
Spartanburg Terminal Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Spartanburg Terminal Co. v. Commissioner
Docket No. 3475-73
United States Tax Court
66 T.C. 916; 1976 U.S. Tax Ct. LEXIS 54;
August 30, 1976, Filed
Decision will be entered under Rule 155.
Petitioner built a railroad tunnel and connecting tracks in downtown Spartanburg, S.C. Held: Petitioner failed to carry his burden to establish a useful life for its grading and tunnel bore. Consequently, no depreciation deductions are allowed with respect to these assets. Also, no investment credit is allowed for these…
2Cases cited26 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- United States v. LudeySupreme Court of the United States · 1927
- Burnet v. Niagara Falls Brewing Co.Supreme Court of the United States · 1931
- Southern Natural Gas Company v. The United StatesUnited States Court of Claims · 1969
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