Commissioner v. Philadelphia Coke Co.
Court of Appeals for the Third Circuit
1Opinion of the Court
JONES, Circuit Judge.
The question in this case is whether expenditures for capital improvements to the property of another made under a contract contemplating the improver’s use of the property for a- definite term shall be amortized on the basis of the term of the contract or on the basis of a shorter period as determined by the earlier termination of the contract through the happening of a specified contingency.
The City of Philadelphia, as owner of a plant for the manufacture of gas, made a lease thereof effective January 1, 1928, to United Gas Improvement Company (hereinafter referred to…
2Cases cited8 opinions
- Bonwit Teller & Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1931
- Philadelphia Gas Works Co. v. PhiladelphiaSupreme Court of Pennsylvania · 1938
- Commissioner of Internal Revenue v. Pittsburgh Athletic Co.Court of Appeals for the Third Circuit · 1934
- 379 Madison Avenue v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1932
- Helvering v. Kansas City American Ass'n Baseball Co.Court of Appeals for the Eighth Circuit · 1935
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3Cited by4 opinions
- Union Electric Co. v. Commissioner of Internal Rev.Court of Appeals for the Eighth Circuit · 1949
- David Dab and Rose Dab v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1958
- Northern Natural Gas Co. v. O'MalleyCourt of Appeals for the Eighth Circuit · 1960
- Northern Natural Gas Company v. John A. O'malley, Administrator of the Estate of George W. O'malley, Deceased, Northern Natural Gas Company v. James L. McCroryCourt of Appeals for the Eighth Circuit · 1960