Chicago Stoker Corp. v. Commissioner
United States Tax Court
Deductible Expense or Purchase Price -- Section 23 (a) (1) (A). -- Payments made during each of the taxable years were purchase price of a business in which the petitioner was acquiring an equity and not expenses deductible as made. Following Judson Mills, 11 T. C. 25.
1Opinion of the Court
OPINION.
MuRdock, Judge-.
The Commissioner contends that the amounts in question are not deductible because they were rentals or other payments required to be made as a condition to the continued use or possession, for the purposes of the trade or business, of property to which the taxpayer was taking title or in which it had an equity, and, therefore, they are not proper deductions under section 23 (a) (1) (A). He relies on such cases as Goldfields of America, Ltd., 44 B. T. A. 200; Judson Mills, 11 T. C. 25; and Truman Bowen, 12 T. C. 446. He does not make any different point as to the part…
2Cases cited4 opinions
- Mills v. CommissionerUnited States Tax Court · 1948
- Bowen v. CommissionerUnited States Tax Court · 1949
- Gilken Corp. v. CommissionerUnited States Tax Court · 1948
- Eaton v. CommissionerUnited States Tax Court · 1948
3Cited by3 opinions
- Ersel H. Beus and Anna Beus, W. J. Beus, and Leone Beus v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1958
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1977
- Chicago Stoker Corp. v. CommissionerUnited States Tax Court · 1950