Sartori v. Commissioner
United States Tax Court
Willowbrook, petitioners' subch. S corporation, entered into negotiations with a manufacturer in October of 1968 to construct a dragline meeting Willowbrook's special specifications for use in its strip-mining operation. At a meeting on Feb. 18, 1969, the manufacturer indicated it thought it could provide such equipment and Willowbrook's representative said that if it could do so, Willowbrook would buy the equipment.
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Willowbrook, petitioners' subch. S corporation, entered into negotiations with a manufacturer in October of 1968 to construct a dragline meeting Willowbrook's special specifications for use in its strip-mining operation. At a meeting on Feb. 18, 1969, the manufacturer indicated it thought it could provide such equipment and Willowbrook's representative said that if it could do so, Willowbrook would buy the equipment. In December of 1969, a proposal by the manufacturer was accepted by Willowbrook, a written contract was entered into in February or March of 1970, and the equipment was delivered…
1Opinion of the Court
Drennen, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes for the taxable year 1970, as follows:
Docket No. Petitioner Deficiency
433-74 David Sartori_ $40,263.42
434-74 James Sartori and Kathleen Sartori_ 40,404.24
As a result of certain concessions made by petitioners, the only issue remaining for decision in these consolidated cases is whether certain property purchased and placed in service in 1970 by Willowbrook Mining Co., petitioners’ wholly owned subchapter S corporation, qualifies as pretermination property under section 49(b), I.R.C. 1954,1 such that…
2Cases cited7 opinions
- Neville Chemical Company v. Union Carbide CorporationCourt of Appeals for the Third Circuit · 1970
- United States v. CalamaroSupreme Court of the United States · 1957
- Litsinger Sign Co. v. American Sign Co.Ohio Supreme Court · 1967
- General Motors Corp. v. Keener Motors, Inc.Court of Appeals for the Sixth Circuit · 1952
- Fahringer v. Strine EstateSupreme Court of Pennsylvania · 1966
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3Cited by8 opinions
- Sunbury Textile Mills, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1978
- Sunbury Textile Mills, Inc. v. CommissionerUnited States Tax Court · 1977
- Erving Paper Mills Corp. v. CommissionerUnited States Tax Court · 1979
- Coffey v. CommissionerUnited States Tax Court · 1985
- Erving Paper Mills Corp. v. CommissionerUnited States Tax Court · 1979
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