Union Electric Co. v. Commissioner
United States Tax Court
1. Deductions -- Depreciation -- Section 23 (l) -- Improvements by Temporary Occupant of Land. -- A licensee may not spread the cost of assets over the term of the license where it had a right either to receive a new license or to be paid for the assets at the end of the term of the license and the assets had a useful life longer than the term of the license. 2. Id. -- Limited Interests in Land and Other Incidental Expenditures. -- Expenditures incident to the construction…
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1. Deductions -- Depreciation -- Section 23 (l) -- Improvements by Temporary Occupant of Land. -- A licensee may not spread the cost of assets over the term of the license where it had a right either to receive a new license or to be paid for the assets at the end of the term of the license and the assets had a useful life longer than the term of the license. 2. Id. -- Limited Interests in Land and Other Incidental Expenditures. -- Expenditures incident to the construction of an hydroelectric power plant, including the cost of limited interests in land, easements, and flowage rights which had…
1Opinion of the Court
OPINION.
Murdock, Judge:
The Commissioner has determined that the probable useful life of the dam is 100 years-, and the probable useful life of the structures and improvements is 60 years, and has allowed deductions for each year of one one-hundredth of the cost of the dam and one-sixtieth of the costs of the structures and improvements. The petitioner does not contest the Commissioner’s determination that the probable useful lives of those assets will extend beyond the 50-year period of the license. It contends that their .useful lives to it are limited by the 50-year term of the license, so…
2Cases cited1 opinion
- United States v. LudeySupreme Court of the United States · 1927
3Cited by12 opinions
- Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
- Algernon Blair, Inc. v. CommissionerUnited States Tax Court · 1958
- Union Electric Co. v. Commissioner of Internal Rev.Court of Appeals for the Eighth Circuit · 1949
- Portland General Electric Company v. United StatesDistrict Court, D. Oregon · 1960
- Kentucky Utilities Company v. GlennDistrict Court, W.D. Kentucky · 1965
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