Shufflebarger v. Commissioner
United States Tax Court
In 1948, the petitioners, by purchase, acquired from the Wingfield brothers 94 1/2 acres of fee land and a waiver of a preference for the summer grazing of 286 head of cattle on what was designated as the Blind Lake Allotment in the Coconino National Forest.
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In 1948, the petitioners, by purchase, acquired from the Wingfield brothers 94 1/2 acres of fee land and a waiver of a preference for the summer grazing of 286 head of cattle on what was designated as the Blind Lake Allotment in the Coconino National Forest. As the result of the acquisition of the fee land and the waiver, the said grazing preference was transferred by the Forest Service from the Wingfields to the petitioners, and based on the ownership of the grazing preference by petitioners, the Forest Service issued to them a grazing permit covering the said allotment for the unexpired…
1Opinion of the Court
OPINION.
TurneR, Judge:
It is the claim of the petitioners that the grazing privileges acquired in 1948 were property used in their trade or business within the meaning of section 23 (1) of the Internal Revenue Code of 1939 5; that their adjusted basis therefor was $25,821.32, being the amount paid the Wingfields, less $490.68, the amount they regard as being properly allocable as the cost of the fee land; that the period over which the useful life of the property will be exhausted is the term of the permit, which as to them was 8 years, namely, 1948 to 1955, inclusive, and as a consequence…
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