Armco, Inc. v. Commissioner
United States Tax Court
1. P is engaged in the production of steel and steel products. For its 1976 and 1977 taxable years, P elected to apply the percentage repair allowance (PRA) for ferrous metals. Under the PRA, an electing taxpayer could deduct currently, as a repair expense, a prescribed percentage of the unadjusted basis of the property within a specified class of assets without challenge from R if it agreed to capitalize any remaining repair expenses attributable to that class.
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1. P is engaged in the production of steel and steel products. For its 1976 and 1977 taxable years, P elected to apply the percentage repair allowance (PRA) for ferrous metals. Under the PRA, an electing taxpayer could deduct currently, as a repair expense, a prescribed percentage of the unadjusted basis of the property within a specified class of assets without challenge from R if it agreed to capitalize any remaining repair expenses attributable to that class. Rev. Proc. 72-10 provided an 8-percent PRA for ferrous metals during the years in issue. R knew the methodology used to derive the…
1Opinion of the Court
Armco, Inc. (Formerly Armco Steel Corporation and Subsidiaries), Petitioner v. Commissioner of Internal Revenue, Respondent
Armco, Inc. v. Commissioner
Docket Nos. 20037-85, 45229-85
United States Tax Court
88 T.C. 946; 1987 U.S. Tax Ct. LEXIS 51; 88 T.C. No. 51;
April 20, 1987. April 20, 1987, Filed
Decisions will be entered under Rule 155.
1. P is engaged in the production of steel and steel products. For its 1976 and 1977 taxable years, P elected to apply the percentage repair allowance (PRA) for ferrous metals. Under the PRA, an electing taxpayer could deduct currently, as a repair expense, a…
2Cases cited21 opinions
- Allen v. WrightSupreme Court of the United States · 1984
- United States v. CorrellSupreme Court of the United States · 1967
- National Muffler Dealers Assn., Inc. v. United StatesSupreme Court of the United States · 1979
- United States v. Vogel Fertilizer Co.Supreme Court of the United States · 1982
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
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