Legal Opinion

Austin Co. v. Commissioner

United States Tax Court

Decided March 5, 1979No. Docket No. 1312-75PublishedCited by 30 opinions

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

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Interstate Transit Lines v. CommissionerSupreme Court of the United States · 1943
  4. Boehm v. CommissionerSupreme Court of the United States · 1945
  5. Enoch v. CommissionerUnited States Tax Court · 1972

20 more not listed; retrieve them via the Exa API.

3Cited by30 opinions

  1. Eli Lilly & Co. v. CommissionerUnited States Tax Court · 1985
  2. Lychuk v. Comm'rUnited States Tax Court · 2001
  3. Robert W. Delk Dorothy A. Delk Michael W. Delk Mary M. Delk v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1997
  4. Noble v. CommissionerUnited States Tax Court · 1982
  5. Coulter Electronics, Inc. v. CommissionerUnited States Tax Court · 1990

25 more not listed; retrieve them via the Exa API.

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