Cotton States Fertilizer Co. v. Commissioner
United States Tax Court
During the taxable year ended June 30, 1952, two of petitioner's plants were destroyed by fire. Petitioner carried fire insurance but in order to present its claims for insurance it employed a firm of architects to recreate plans and specifications and a contractor to estimate the replacement cost of the destroyed plants. As a result of such claims petitioner recovered insurance proceeds exceeding the adjusted basis of the plants.
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During the taxable year ended June 30, 1952, two of petitioner's plants were destroyed by fire. Petitioner carried fire insurance but in order to present its claims for insurance it employed a firm of architects to recreate plans and specifications and a contractor to estimate the replacement cost of the destroyed plants. As a result of such claims petitioner recovered insurance proceeds exceeding the adjusted basis of the plants. It placed the proceeds in a "replacement" account and used such proceeds in replacing the destroyed property, the cost of which exceeded the proceeds, and in…
1Opinion of the Court
Cotton States Fertilizer Company, Petitioner, v. Commissioner of Internal Revenue, Respondent
Cotton States Fertilizer Co. v. Commissioner
Docket No. 59879
United States Tax Court
28 T.C. 1169; 1957 U.S. Tax Ct. LEXIS 91;
September 16, 1957, Filed
Decision will be entered under Rule 50.
During the taxable year ended June 30, 1952, two of petitioner's plants were destroyed by fire. Petitioner carried fire insurance but in order to present its claims for insurance it employed a firm of architects to recreate plans and specifications and a contractor to estimate the replacement cost of the destroyed…
2Cases cited4 opinions
- Ticket Office Equipment Co. v. CommissionerUnited States Tax Court · 1953
- National Engraving Co. v. CommissionerUnited States Tax Court · 1944
- Cotton States Fertilizer Co. v. CommissionerUnited States Tax Court · 1957
- Donald B. Jones & Mercy P. Jones v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1956