Legal Opinion

Cal-Maine Foods, Inc. v. Commissioner

United States Tax Court

Decided March 30, 1977No. Docket Nos. 7092-74, 7093-74Unpublished

Farms entered into an agreement entitled "Agreement of Lease" providing for the construction by the lessor of specific improvements on a particular parcel of land and monthly payments by Farms based upon the lessor's total original cost.

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Farms entered into an agreement entitled "Agreement of Lease" providing for the construction by the lessor of specific improvements on a particular parcel of land and monthly payments by Farms based upon the lessor's total original cost. The agreement contained an option under which Farms was entitled to purchase the leased premises at the end of the primary term of the lease, or at the end of any extension thereof, for a specified percentage of the lessor's total original cost. The Commissioner determined that the monthly payments under the agreement constituted capital expenditures and thus…

1Opinion of the Court

CAL-MAINE FOODS, INC., SUCCESSOR TO ADAMS EGG FARMS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

CAL-MAINE FOODS, INC., SUCCESSOR TO ADAMS FOODS, INC., (FORMERLY SIMPSON COUNTY HATCHERY, INC.) Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Cal-Maine Foods, Inc. v. Commissioner

Docket Nos. 7092-74, 7093-74.

United States Tax Court

T.C. Memo 1977-89; 1977 Tax Ct. Memo LEXIS 352; 36 T.C.M. (CCH) 383; T.C.M. (RIA) 770089;

March 30, 1977, Filed

Farms entered into an agreement entitled "Agreement of Lease" providing for the construction by the lessor of specific…

2Cases cited18 opinions

  1. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  2. Walburga Oesterreich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
  3. Haggard v. CommissionerUnited States Tax Court · 1955
  4. D. M. Haggard and Nila Haggard v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
  5. Mills v. CommissionerUnited States Tax Court · 1948

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