Ambrose v. Commissioner
United States Tax Court
Section 124 (d) (1), (4) -- Amortization of Emergency Facility. -- Petitioner owned an emergency facility. He elected to take amortization deductions under sections 23 (t) and 124 (a), I. R. C., on the basis of the 60-month amortization period allowed. He owned the property from January 1943, until June 7, 1945, when it was taken under condemnation proceedings by the United States Government.
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Section 124 (d) (1), (4) -- Amortization of Emergency Facility. -- Petitioner owned an emergency facility. He elected to take amortization deductions under sections 23 (t) and 124 (a), I. R. C., on the basis of the 60-month amortization period allowed. He owned the property from January 1943, until June 7, 1945, when it was taken under condemnation proceedings by the United States Government. He made the election under sections 124 (d) (1) and (4) to retroactively recompute amortization deductions on the basis of a 32 month amortization period ending September 30, 1945, the end of the…
1Opinion of the Court
OPINION.
HaRRON, Judge:
The question is whether the petitioner is entitled, under section 124 (d) (4) of the Code, to have income tax for 1943 recomputed to give effect to a retroactive revision of the amount of the amortization deduction on the emergency facility which he owned. He owned the property in 1945 for a period of 6 months until it was taken by the United States Government under condemnation proceedings on June 7, 1945, and in bis income tax return for 1945 be computed tbe amortization deduction on tbe basis of an amortization period of 32 months, i. e., from February 1943, to and…
2Cases cited2 opinions
- Ken-Rad Tube & Lamp Corp. v. CommissionerUnited States Tax Court · 1948
- Ken-Rad Tube & Lamp Corp. v. Commissioner of Internal Revenue. Ken-Rad Transmitting Tube Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1950
3Cited by3 opinions
- Avco Mfg. Corp. v. CommissionerUnited States Tax Court · 1956
- Ambrose v. CommissionerUnited States Tax Court · 1952
- Avco Mfg. Corp. v. CommissionerUnited States Tax Court · 1956