Central Citrus Co. v. Commissioner
United States Tax Court
In its 1968 fiscal period petitioner constructed a plant for the processing of citrus fruit. Within one-sixth of the plant area it erected processing compartments, commonly referred to as sweet rooms, wherein fruit while stored was subjected to various controlled atmospheric conditions so as to govern its quality prior to packaging. The remaining floorspace contained the plant's general work area.
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In its 1968 fiscal period petitioner constructed a plant for the processing of citrus fruit. Within one-sixth of the plant area it erected processing compartments, commonly referred to as sweet rooms, wherein fruit while stored was subjected to various controlled atmospheric conditions so as to govern its quality prior to packaging. The remaining floorspace contained the plant's general work area. Petitioner also installed, among other things, blowers and coolers utilized to lower the temperature in the general work area, and various items of electrical equipment and lighting fixtures. Held,…
1Opinion of the Court
Stekrett, Judge:
The Commissioner determined deficiencies in petitioner’s Federal income tax as follows:
Taxable year Apiount
June 30, 1966. $1,108. 03
June 30, 1967. 3, 851. 91
The sole issue for adjudication is whether specific property1 constructed or installed by petitioner qualifies as “section 38 property” as defined within the provisions of section 48, I.R.C. 1954.2
Petitioner on its September 30, 1968,3 Federal income tax return claimed an investment credit of $24,069. It applied this amount to its taxable income for tlh!at year of $15,799. Tbe remaining credit was carried back to its 1966…
2Cases cited8 opinions
- Catron v. CommissionerUnited States Tax Court · 1968
- Northville Dock Corp. v. CommissionerUnited States Tax Court · 1969
- Commissioner of Internal Revenue v. Schuyler Grain Co., Inc.Court of Appeals for the Seventh Circuit · 1969
- Schuyler Grain Co. v. CommissionerUnited States Tax Court · 1968
- Ft. Walton Square, Inc. v. CommissionerUnited States Tax Court · 1970
3 more not listed; retrieve them via the Exa API.
3Cited by47 opinions
- Brown-Forman Distillers Corp. v. United StatesUnited States Court of Claims · 1974
- Scott Paper Co. v. CommissionerUnited States Tax Court · 1980
- Yellow Freight System, Inc. v. United StatesCourt of Appeals for the Eighth Circuit · 1976
- Satrum v. CommissionerUnited States Tax Court · 1974
- Illinois Cereal Mills, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
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