Legal Opinion

Selig v. Commissioner

United States Tax Court

Decided October 31, 1995No. Docket No. 19151-93UnpublishedCited by 1 opinion

P exhibited "exotic automobiles", state-of-the-art, high technology vehicles with unique design features or equipment, for a fee. Ps claimed depreciation deductions for such automobiles.

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P exhibited "exotic automobiles", state-of-the-art, high technology vehicles with unique design features or equipment, for a fee. Ps claimed depreciation deductions for such automobiles. P's wholly owned S corporation made expenditures related to P's plans to open an exotic car entertainment complex. 1. Held: The exotic automobiles were subject to obsolescence and, thus, were depreciable under secs. 167 and 168, I.R.C. 2. Held, further, the expenditures made by P's wholly owned S corporation are nondeductible under sec. 162(a), I.R.C., on account of being preopening expenses not incurred in a…

1Opinion of the Court

BRUCE SELIG AND ELAINE SELIG, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Selig v. Commissioner

Docket No. 19151-93.

United States Tax Court

T.C. Memo 1995-519; 1995 Tax Ct. Memo LEXIS 518; 70 T.C.M. (CCH) 1125;

October 31, 1995, Filed

Decision will be entered under Rule 155.

P exhibited "exotic automobiles", state-of-the-art, high technology vehicles with unique design features or equipment, for a fee. Ps claimed depreciation deductions for such automobiles. P's wholly owned S corporation made expenditures related to P's plans to open an exotic car entertainment complex.

1. Held: The…

2Cases cited13 opinions

  1. Pallottini v. CommissionerUnited States Tax Court · 1988
  2. Mailman v. CommissionerUnited States Tax Court · 1988
  3. Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
  4. Richmond Television Corp. v. United StatesSupreme Court of the United States · 1965
  5. Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965

8 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Rooney v. Comm'rUnited States Tax Court · 2011

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