State Farm Road Corp. v. Commissioner
United States Tax Court
Petitioner was in the business of constructing and operating sewage disposal and treatment facilities and financed its construction costs by levying "tie-in" charges against prospective customers. Held, receipts from tie-in charges are not contributions to capital and are includable in petitioner's gross income.
1Opinion of the Court
State Farm Road Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
State Farm Road Corp. v. Commissioner
Docket No. 3720-74
United States Tax Court
65 T.C. 217; 1975 U.S. Tax Ct. LEXIS 41;
November 3, 1975, Filed
Decision will be entered for the respondent.
Petitioner was in the business of constructing and operating sewage disposal and treatment facilities and financed its construction costs by levying "tie-in" charges against prospective customers. Held, receipts from tie-in charges are not contributions to capital and are includable in petitioner's gross income.
Robert V.…
2Cases cited20 opinions
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
- New York Trust Co. v. EisnerSupreme Court of the United States · 1921
- Commissioner v. LoBueSupreme Court of the United States · 1956
- United States v. Skelly Oil Co.Supreme Court of the United States · 1969
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
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