Gray v. Commissioner
United States Tax Court
Petitioner is held to be not entitled to deductions for amortization of war facilities under section 124, Internal Revenue Code, where no application for certificate of necessity was timely filed and no certificate of necessity was issued.
1Opinion of the Court
OPINION.
Leech, Judge:
Section 124, Internal Revenue Code, provides for the allowance of a deduction with respect to amortization over a period of 60 months of the adjusted basis (for determining gain) of any emergency facility. Subsection (e) defines emergency facility as follows:(1) Emebgetict Facility. — As used in this section, the' term “emergency facility” means any facility, land, building, machinery, or equipment, or part thereof, the construction, reconstruction, erection, installation, or acquisition of which was completed after December 31, 1939, and with respect to which a…
2Cases cited2 opinions
- United States v. LombardoSupreme Court of the United States · 1916
- American Twist Drill Co. v. CommissionerUnited States Tax Court · 1948
3Cited by13 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Penn-Dixie Steel Corp. v. CommissionerUnited States Tax Court · 1978
- Simms v. CommissionerUnited States Tax Court · 1951
- Estate of Fred B. Fisk v. CommissionerUnited States Tax Court · 1952
- Lobo v. CommissionerUnited States Tax Court · 1988
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