Charles Baloian Co. v. Commissioner
United States Tax Court
On Feb. 25, 1971, petitioner was advised by the Redevelopment Agency of the City of Fresno that the building in which it was leasing its place of business was scheduled for demolition and that it had at least 90 days to vacate such building. On May 20, 1971, the agency issued to petitioner a written authorization to incur moving expenses in a specified amount. Subsequently, petitioner actually moved, incurred moving expenses, and was partially reimbursed.
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On Feb. 25, 1971, petitioner was advised by the Redevelopment Agency of the City of Fresno that the building in which it was leasing its place of business was scheduled for demolition and that it had at least 90 days to vacate such building. On May 20, 1971, the agency issued to petitioner a written authorization to incur moving expenses in a specified amount. Subsequently, petitioner actually moved, incurred moving expenses, and was partially reimbursed. Three persons owned all of the stock of petitioner and 78 percent of the stock of Pam-Pak, a fourth person (Torigian) owned the remaining…
1Opinion of the Court
Forrester, Judge:
Respondent has determined the following deficiencies in petitioner’s Federal income tax:
TYE June 30— Deficiency
1971. $16,934.61
1972. 12,750.34
Concessions having been made, the following issues are presented for our decision:(1) Whether petitioner is entitled to deduct moving expenses incurred and accrued in its fiscal year ended June 30, 1971, and, if such deduction is allowable, whether the amount of subsequent reimbursement for such expenses is includable in its gross income; and(2) Whether petitioner and Pam-Pak Distributors, Inc., constitute a "brother-sister controlled…
2Cases cited12 opinions
- Continental Tie & Lumber Co. v. United StatesSupreme Court of the United States · 1932
- Patchen v. CommissionerUnited States Tax Court · 1956
- Hearn v. CommissionerUnited States Tax Court · 1961
- Charles F. Dally and Sarafrancis Dally v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Fairfax Auto Parts, Inc. v. CommissionerUnited States Tax Court · 1976
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3Cited by29 opinions
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- Manocchio v. CommissionerUnited States Tax Court · 1982
- Allen Oil Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1980
- Wolfers v. CommissionerUnited States Tax Court · 1978
- Delta Metalforming Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1980
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