Legal Opinion
Pelaez and Sons, Inc. v. Commissioner
United States Tax Court
Decided May 30, 2000No. 18049-97Unknown
1Opinion of the Court
114 T.C. No. 28
UNITED STATES TAX COURT PELAEZ AND SONS, INC., CHRISTINA P. HOOKER, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 18049-97. Filed May 30, 2000. Sec. 263A, I.R.C., enacted in 1986, requires the capitalization of developmental costs. For plants with preproduction periods that are 2 years or less, farmers may be excepted from the capitalization requirements. For certain plants, including citrus plants grown in commercial quantities in the United States, the statute requires that the standard for the 2-year test is to be based on a…
2Cases cited14 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
- Sullivan v. StroopSupreme Court of the United States · 1990
- Graff Chevrolet Company v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
- First Chicago Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
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