Southern Pacific Transp. Co. v. Commissioner
United States Tax Court
Held: The parties, in making the computation pursuant to Rule 155, Tax Court Rules of Practice and Procedure, shall be guided by the following: 1. Relay Rail Issue: The adjustment under sec. 481(a), I.R.C. 1954, restoring improperly deducted amounts to income, shall be made entirely in the year 1959. 2. Historical Costs Issue: To the extent that petitioner used the "ICC amounts" on its returns to establish the tax basis of any of the pre-1914 assets at issue in this case,…
Read the full summary
Held: The parties, in making the computation pursuant to Rule 155, Tax Court Rules of Practice and Procedure, shall be guided by the following: 1. Relay Rail Issue: The adjustment under sec. 481(a), I.R.C. 1954, restoring improperly deducted amounts to income, shall be made entirely in the year 1959. 2. Historical Costs Issue: To the extent that petitioner used the "ICC amounts" on its returns to establish the tax basis of any of the pre-1914 assets at issue in this case, such amounts shall be utilized in the computation to reflect the tax basis of those assets, and not any costs purportedly…
1Opinion of the Court
SUPPLEMENTAL OPINION
Drennen, Judge:
Our opinion in this matter called for the decision to be entered under Rule 155, Tax Court Rules of Practice and Procedure. See Southern Pacific Transportation Co. v. Commissioner, 75 T.C. 497, 850 (1980). The parties have submitted their computations under Rule 155, and for the most part they are in accord.
The parties have advised the Court that they are in disagreement as to two points. One matter of disagreement arises in connection with the portion of our opinion entitled "Issues (1) and (ccc): Relay Rail” (see 75 T.C. at 498, 726-746), and the other…
2Cases cited6 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Coors v. CommissionerUnited States Tax Court · 1973
- Adolph Coors Company v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1975
- United States v. MathesonCourt of Appeals for the Second Circuit · 1976
- Estate of Stein v. CommissionerUnited States Tax Court · 1963
1 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- FPL Group, Inc. v. CommissionerUnited States Tax Court · 2000
- Capitol Fed. Sav. & Loan Ass'n v. CommissionerUnited States Tax Court · 1991
- Diebold, Inc. v. United StatesUnited States Court of Claims · 1989
- Pacific Enters. & Subsidiaries v. CommissionerUnited States Tax Court · 1993
- Lehigh Valley Rail Mgmt. LLC v. County of Northampton Revenue Appeals Board and County of Northampton ~ Appeal of: County of NorthamptonCommonwealth Court of Pennsylvania · 2018
11 more not listed; retrieve them via the Exa API.