CRST, Inc. v. Commissioner
United States Tax Court
Petitioner may not deduct as an abandonment loss in 1980 the decrease in value of its certificates of convenience and necessity or operating authority incurred as a result of the deregulation of the motor carrier business by the Interstate Commerce Commission.
1Opinion of the Court
Drennen, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax liability as follows:
Year Deficiency
1977. $94,293
1978. 320,775
1979. 37,082
1980. 477,036
After concessions, the sole issue for our consideration is whether petitioner is entitled to deduct the decrease in value of certain Interstate Commerce Commission (ICC) certificates of operating authority, incurred as a result of deregulation, as a section 1651 abandonment loss.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein…
2Cases cited11 opinions
- Second Employers'liability CasesSupreme Court of the United States · 1912
- New York Central Railroad Company v. WhiteSupreme Court of the United States · 1916
- United States v. S. S. White Dental Manufacturing Co.Supreme Court of the United States · 1927
- A. J. Industries, Inc. v. United StatesCourt of Appeals for the Ninth Circuit · 1974
- Reporter Pub. Co., Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1953
6 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Citron v. CommissionerUnited States Tax Court · 1991
- Standley v. CommissionerUnited States Tax Court · 1992
- Hovhannissian v. CommissionerUnited States Tax Court · 1997
- CRST, Inc. v. CommissionerUnited States Tax Court · 1989
- Citron v. CommissionerUnited States Tax Court · 1991
3 more not listed; retrieve them via the Exa API.