Austin Co. v. Commissioner
United States Tax Court
Held, petitioner's 12-year useful life on depreciable equipment approved. Held, further, loan expenses have indeterminable useful life and therefore are not subject to amortization.
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Held, petitioner's 12-year useful life on depreciable equipment approved. Held, further, loan expenses have indeterminable useful life and therefore are not subject to amortization. Held, further, petitioner's expenses incurred in reimbursing a foreign subsidiary for foreign taxes it paid are not deductible under sec. 162, I.R.C. 1954. Held, further: Petitioner's stock and debt in a foreign subsidiary were worthless in its fiscal year ended June 30, 1971; accordingly, it is entitled to an ordinary loss under secs. 165(g) and 166(a)(2), I.R.C. 1954. Petitioner's worthless and deductible debt,…
1Opinion of the Court
Wiles, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
FYE June 30th— Deficiency
1969 . $112,172.76
1970 . 231,963.31
1971 . 179,883.22
After concessions, the issues remaining for decision are:(1) Whether petitioner is entitled to utilize an estimated useful life of 12 years for depreciable property acquired in fiscal years 1969,1970, and 1971;(2) Whether petitioner is entitled to a fiscal year 1969 deduction for loan financing expenses paid in that year;(3) Whether petitioner is entitled to a deduction under section 162(a)1 for Mexican taxes it paid in…
2Cases cited25 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
- Boehm v. CommissionerSupreme Court of the United States · 1945
- Enoch v. CommissionerUnited States Tax Court · 1972
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- Noble v. CommissionerUnited States Tax Court · 1982
- Coulter Electronics, Inc. v. CommissionerUnited States Tax Court · 1990
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