Kansas City S. Indus. v. Commissioner
United States Tax Court
P was the parent of members of a consolidated group, including two subsidiaries conducting railroad operations. For the taxable calendar years 1970 through 1976, P elected to amortize railroad grading pursuant to sec. 185, I.R.C. In 1977, P filed an application to revoke the election for years after 1976. Held, denial of P's application to revoke the election was an abuse of discretion because its purpose was to prevent P's reliance on favorable Court precedent.
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P was the parent of members of a consolidated group, including two subsidiaries conducting railroad operations. For the taxable calendar years 1970 through 1976, P elected to amortize railroad grading pursuant to sec. 185, I.R.C. In 1977, P filed an application to revoke the election for years after 1976. Held, denial of P's application to revoke the election was an abuse of discretion because its purpose was to prevent P's reliance on favorable Court precedent. Held, further, P was not required to recognize income from sidetrack deposits at the time that construction pursuant to industry…
1Opinion of the Court
Kansas City Southern Industries, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Kansas City S. Indus. v. Commissioner
Docket Nos. 18653-87, 17654-88
United States Tax Court
98 T.C. 242; 1992 U.S. Tax Ct. LEXIS 22; 98 T.C. No. 19;
March 5, 1992, Filed
Decisions will be entered under Rule 155.
P was the parent of members of a consolidated group, including two subsidiaries conducting railroad operations. For the taxable calendar years 1970 through 1976, P elected to amortize railroad grading pursuant to sec. 185, I.R.C. In 1977, P filed an application to revoke the election for years…
2Cases cited29 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- Mailman v. CommissionerUnited States Tax Court · 1988
- Commissioner v. Indianapolis Power & Light Co.Supreme Court of the United States · 1990
- Ronnen v. CommissionerUnited States Tax Court · 1988
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
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