Coors v. Commissioner
United States Tax Court
Held: 1. Where the Commissioner did not concede the correctness of the company's accounting treatment of its self-constructed assets in abandoning capitalization adjustments in litigation involving the company for prior years, the doctrines of res judicata and collateral estoppel do not apply to the present litigation. 2. The company's method of accounting for its self-constructed assets does not clearly reflect its income on an annual basis and is erroneous for Federal…
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Held: 1. Where the Commissioner did not concede the correctness of the company's accounting treatment of its self-constructed assets in abandoning capitalization adjustments in litigation involving the company for prior years, the doctrines of res judicata and collateral estoppel do not apply to the present litigation. 2. The company's method of accounting for its self-constructed assets does not clearly reflect its income on an annual basis and is erroneous for Federal income tax purposes. Costs of its self-constructed assets represent capital expenditures under sec. 263, I.R.C. 1954. 3. The…
1Opinion of the Court
DawsoN, Judge:*
Respondent determined the following deficiencies in the Federal income taxes of petitioners:
Docket No. Year Deficiency 2837-69 1966 $3,926.00 2839-69 1966 7,952.00 1966 7,803.00 2840-69 1966 3,838,154.33 1966 1,268,786.83 Petitioners William K. Coors and Phyllis E. Coors. Joseph Coors and Holly H. Coors_ Adolph Coors Co_.
Various concessions have been made by the parties and will be given effect in the Rule 50 computations. The issues remaining for decision are:(1) Whether the doctrines of res judicata and collateral estoppel apply to certain capitalization adjustments made by…
2Cases cited68 opinions
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Cromwell v. County of SacSupreme Court of the United States · 1877
- Lawlor v. National Screen Service Corp.Supreme Court of the United States · 1955
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
- Angel v. BullingtonSupreme Court of the United States · 1947
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3Cited by97 opinions
- Allen v. CommissionerUnited States Tax Court · 1979
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- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Curphey v. CommissionerUnited States Tax Court · 1980
- Madison Gas & Electric Co. v. CommissionerUnited States Tax Court · 1979
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