Polachek v. Commissioner
United States Board of Tax Appeals
1. The amortization provision must be construed to preserve its national significance, whatever may be the result of such construction locally for a single year upon a single taxpayer. 2. The amortization provision is alleviative and, so far as consistent with its broad purpose, it should be specifically applied liberally. 3. The amortization deduction is an extraordinary one growing out of the war, and, unlike the deductions for exhaustion, obsolescence or loss, is…
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1. The amortization provision must be construed to preserve its national significance, whatever may be the result of such construction locally for a single year upon a single taxpayer. 2. The amortization provision is alleviative and, so far as consistent with its broad purpose, it should be specifically applied liberally. 3. The amortization deduction is an extraordinary one growing out of the war, and, unlike the deductions for exhaustion, obsolescence or loss, is unrelated to the normal determination of net income. 4. The amortization deduction was provided, not as an essential factor in…
1Opinion of the Court
JOHN POLACHEK, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.
Polachek v. Commissioner
Docket No. 7678.
United States Board of Tax Appeals
8 B.T.A. 1; 1927 BTA LEXIS 2965;
September 9, 1927, Promulgated
1. The amortization provision must be construed to preserve its national significance, whatever may be the result of such construction locally for a single year upon a single taxpayer.
2. The amortization provision is alleviative and, so far as consistent with its broad purpose, it should be specifically applied liberally.
3. The amortization deduction is an extraordinary one growing out…
2Cases cited7 opinions
- LaBelle Iron Works v. United StatesSupreme Court of the United States · 1921
- Manville Jenckes Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Walcott Lathe Co. v. CommissionerUnited States Board of Tax Appeals · 1925
- American-Hawaiian S.S. Co. v. CommissionerUnited States Board of Tax Appeals · 1927
- Polachek v. CommissionerUnited States Board of Tax Appeals · 1927
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