Illinois C. R. Co. v. Commissioner
United States Board of Tax Appeals
1. In 1926 one of the affiliated petitioners, as lessee, leased certain railroad properties for a period of approximately 350 years, with options to renew for an additional period of 999 years.
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1. In 1926 one of the affiliated petitioners, as lessee, leased certain railroad properties for a period of approximately 350 years, with options to renew for an additional period of 999 years. The lease contracts required the lessee, at its own cost and expense, to repair, replace, and renew the leased properties so as to maintain them in as good condition as at the date of the agreements, but the lessors were to reimburse the lessee for all additions, betterments, and improvements. Held (a) that the lessee is not entitled to deductions representing the cost to the lessors, less salvage…
1Opinion of the Court
OPINION.
Trammell:
Respondent determined deficiencies in income tax of $27,088.88 for 1926, $84,611.39 for 1927, $46,663.09 for 1928, and $29,463.82 for 1929. Petitioners allege that respondent’s determinations are erroneous in that as to each taxable year he did not deduct from the income of the Yazoo & Mississippi Valley Railroad Co. the cost of replacements of leased property. The respondent claims increased deficiencies for all of the taxable years, alleging that he erred in allowing deductions from the income of the Yazoo & Mississippi Valley Railroad Co. (1) of $142,248.26 for 1926,…
2Cases cited5 opinions
- Lucas v. American Code Co.Supreme Court of the United States · 1930
- Weiss v. WeinerSupreme Court of the United States · 1929
- Duffy v. Central R. Co. of NJSupreme Court of the United States · 1925
- Michigan Cent. R.R. v. CommissionerUnited States Board of Tax Appeals · 1933
- New York, C. & S. L. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1932
3Cited by2 opinions
- Illinois C. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
- Illinois Cent R.R. v. CommissionerUnited States Board of Tax Appeals · 1936