Munford, Inc. v. Commissioner
United States Tax Court
During its taxable year ended Dec. 30, 1976, petitioner placed in service an addition to a refrigerated facility for the storage of frozen food products. The addition comprised a 3,900 square foot truck loading platform, a 1,030-square-foot rail loading platform and a 34,650-square-foot refrigerated area.
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During its taxable year ended Dec. 30, 1976, petitioner placed in service an addition to a refrigerated facility for the storage of frozen food products. The addition comprised a 3,900 square foot truck loading platform, a 1,030-square-foot rail loading platform and a 34,650-square-foot refrigerated area. Petitioner sought an investment tax credit under sec. 38, I.R.C. 1954, with respect to costs relating to the addition, contending that the structure constitutes tangible personal property under sec. 48(a)(1)(A). Respondent allowed the credit only with respect to certain refrigeration system…
1Opinion of the Court
Munford, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Munford, Inc. v. Commissioner
Docket No. 13720-83
United States Tax Court
87 T.C. 463; 1986 U.S. Tax Ct. LEXIS 62; 87 T.C. No. 25;
August 18, 1986, Filed
Decision will be entered under Rule 155.
During its taxable year ended Dec. 30, 1976, petitioner placed in service an addition to a refrigerated facility for the storage of frozen food products. The addition comprised a 3,900 square foot truck loading platform, a 1,030-square-foot rail loading platform and a 34,650-square-foot refrigerated area. Petitioner sought an…
2Cases cited37 opinions
- United States v. ScovilSupreme Court of the United States · 1955
- Catron v. CommissionerUnited States Tax Court · 1968
- Woods Inv. Co. v. CommissionerUnited States Tax Court · 1985
- Evans v. CommissionerUnited States Tax Court · 1967
- Whiteco Indus. v. Comm'rUnited States Tax Court · 1975
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