Cincinnati Transit, Inc. v. Commissioner
United States Tax Court
In 1969 respondent mailed a notice of deficiency to The Cincinnati Transit Company determining deficiencies in its income taxes for the years 1956-64. In 1968 Transit Company caused to be organized Cincinnati Transit, Inc., a wholly owned subsidiary, and entered into an agreement with it transferring to Transit, Inc., certain assets and liabilities relating to the operation of a public transportation system in exchange for the stock of Transit, Inc. Thereafter Transit, Inc.,…
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In 1969 respondent mailed a notice of deficiency to The Cincinnati Transit Company determining deficiencies in its income taxes for the years 1956-64. In 1968 Transit Company caused to be organized Cincinnati Transit, Inc., a wholly owned subsidiary, and entered into an agreement with it transferring to Transit, Inc., certain assets and liabilities relating to the operation of a public transportation system in exchange for the stock of Transit, Inc. Thereafter Transit, Inc., operated the transportation system but Transit Company has assets and is currently doing business in the State of Ohio.…
1Opinion of the Court
OPINION
Drennen, Judge:
Respondent issued a notice of deficiency dated November 17, 1969, to petitioner The Cincinnati Transit Company (hereinafter Transit Co.), determining deficiencies in income tax of Transit Co. for the years 1956 through 1964 as follows:
Year Deficiency
1956 _$123, 648.83
1957 _ 107,068.46
1958 _ 85,225. 33
1959 _ 72,483.33
1960 _ 120,603.12
Year Deficiency
1961_ $57, 658. 92
1962 - 78,231.25
1963 _ 442,416.86
1964_ 170,508.54
The principal adjustments made by respondent which gave rise to the deficiencies were adjustments in depreciation allowable on Transit Co.’s transportation…
2Cases cited13 opinions
- Helvering v. Morgan's, Inc.Supreme Court of the United States · 1934
- International Union, United Automobile, Aerospace & Agricultural Implement Workers, Local 283 v. ScofieldSupreme Court of the United States · 1965
- Krueger v. CommissionerUnited States Tax Court · 1967
- Thomas A. Daboul, and A. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1970
- Louisiana Naval Stores, Inc. v. CommissionerUnited States Board of Tax Appeals · 1929
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3Cited by26 opinions
- Katz v. CommissionerUnited States Tax Court · 2000
- Peninsula Steel Products & Equipment Co. v. CommissionerUnited States Tax Court · 1982
- Claire Morse v. United StatesCourt of Appeals for the Ninth Circuit · 1974
- Sampson v. CommissionerUnited States Tax Court · 1983
- Cincinnati Transit, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1972
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