Ocrant v. Commissioner
United States Tax Court
Held: Depreciation deductions to be claimed for a short taxable year may be computed pursuant to the "averaging convention" authorized by sec. 1.167(a)-10(b), Income Tax Regs., at one-half the rate applicable for the short taxable year. The depreciation deduction is not intended to reflect the decline in the fair market value of an asset, but to enable its owner to charge its cost off over its useful life.
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Held: Depreciation deductions to be claimed for a short taxable year may be computed pursuant to the "averaging convention" authorized by sec. 1.167(a)-10(b), Income Tax Regs., at one-half the rate applicable for the short taxable year. The depreciation deduction is not intended to reflect the decline in the fair market value of an asset, but to enable its owner to charge its cost off over its useful life. Held, an investment credit could not be claimed with respect to certain assets where petitioners failed to prove that the assets were not used by the same parties before and after they were…
1Opinion of the Court
Lawrence Ocrant and Nancy H. Ocrant, Petitioners v. Commissioner of Internal Revenue, Respondent
Ocrant v. Commissioner
Docket No. 6200-73
United States Tax Court
65 T.C. 1156; 1976 U.S. Tax Ct. LEXIS 143;
March 23, 1976, Filed
Decision will be entered for the respondent.
Held: Depreciation deductions to be claimed for a short taxable year may be computed pursuant to the "averaging convention" authorized by sec. 1.167(a)-10(b), Income Tax Regs., at one-half the rate applicable for the short taxable year. The depreciation deduction is not intended to reflect the decline in the fair market value of an…
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Coca-Cola Bottling Co. v. United StatesUnited States Court of Claims · 1973
- Scovill Mfg. Co. v. CommissionerUnited States Board of Tax Appeals · 1932
- Estate of Roodner v. CommissionerUnited States Tax Court · 1975
- Ocrant v. CommissionerUnited States Tax Court · 1976
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