Moraine Hotel Co. v. Commissioner
United States Board of Tax Appeals
1. A reserve set up by the Commissioner in the amount of depreciation deductions claimed and allowed in prior years but not reflected in the books, held prima facie correct and the reserve affirmed where the evidence failed to establish that replacements and repairs, charged to expense, adequately offset depreciation sustained. 2. Special assessment denied upon the evidence.
1Opinion of the Court
*913OPINION.
Siefkin:
[Respecting the respondent’s reduction of petitioner’s surplus due to setting up a reserve for depreciation for years prior to 1917, the essential facts to the controversy lend themselves to brief restatement. To the close of 1916 petitioner had never taken any depreciation on its books, excepting a charge-off as of January 1, 1913, in an amount equal to 10 per cent of its asset account. In such prior years it had, however, charged all replacements and repairs to expense. In addition to thus offsetting depreciation petitioner had, during the years 1909 to 1916, inclusive,…
2Cited by1 opinion
- Moraine Hotel Co. v. CommissionerUnited States Board of Tax Appeals · 1929