Pacific Fruit Express Co. v. Commissioner
United States Tax Court
The petitioner, in computing its deduction for depreciation with respect to its railroad cars, adopted a class life in accordance with Rev. Proc. 62-21, 1962-2 C.B. 418, as amended, and met the reserve ratio test set forth therein without regard to the transition rules. During the years in issue, it made repairs on such cars.
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The petitioner, in computing its deduction for depreciation with respect to its railroad cars, adopted a class life in accordance with Rev. Proc. 62-21, 1962-2 C.B. 418, as amended, and met the reserve ratio test set forth therein without regard to the transition rules. During the years in issue, it made repairs on such cars. Held, any such repairs that appreciably extended the useful life of a railroad car were capital expenditures not deductible under sec. 162, I.R.C. 1954, and the determination of whether such repairs did appreciably extend the useful life of a railroad car is made on an…
1Opinion of the Court
Pacific Fruit Express Company, Petitioner v. Commissioner of Internal Revenue, Respondent
Pacific Fruit Express Co. v. Commissioner
Docket No. 1274-71
United States Tax Court
60 T.C. 640; 1973 U.S. Tax Ct. LEXIS 89; 60 T.C. No. 68;
July 30, 1973, Filed
The petitioner, in computing its deduction for depreciation with respect to its railroad cars, adopted a class life in accordance with Rev. Proc. 62-21, 1962-2 C.B. 418, as amended, and met the reserve ratio test set forth therein without regard to the transition rules. During the years in issue, it made repairs on such cars. Held, any such repairs…
2Cases cited16 opinions
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
- Helvering v. ReynoldsSupreme Court of the United States · 1941
- Illinois Merchants Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Joseph Merrick Jones and Eugenie Penick Jones v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Oberman Mfg. Co. v. CommissionerUnited States Tax Court · 1967
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