Legal Opinion

Hoboken Land & Improv. Co. v. Commissioner

United States Board of Tax Appeals

Decided March 10, 1942No. Docket Nos. 102779, 103902PublishedCited by 9 opinions

1. In years prior to 1934 the petitioner claimed and was allowed depreciation on a class of assets designated as "Piers and Waterfront Properties" in an amount exceeding the cost of the depreciable assets included therein.

Read the full summary

1. In years prior to 1934 the petitioner claimed and was allowed depreciation on a class of assets designated as "Piers and Waterfront Properties" in an amount exceeding the cost of the depreciable assets included therein. Held, that the petitioner is not entitled to depreciation allowances in respect of such depreciable assets for the years 1934, 1936, and 1937. 2. In its income tax returns for 1933 and 1934 the petitioner deducted from gross income as accruals of real property taxes amounts of such taxes which became due and payable during those years. It did not pay during those years the…

1Opinion of the Court

OPINION.

Smith:

These proceedings consolidated for hearing, are for the redetermination of deficiencies in income tax for the years 1934, 1936, and 1937 as follows:

[[Image here]]

Tiñere are four principal issues, which will be treated separately. Briefly stated they are as follows:(1) Whether petitioner is entitled to deductions for depreciation on certain piers and waterfront properties for the years 1934,1936, and 1937.(2) Whether a deduction for accrued property taxes taken in the year 1934 should be adjusted in the light of the subsequent abatement of taxes or whether such abatement and a…

2Cases cited3 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Helvering v. Southwest Consolidated Corp.Supreme Court of the United States · 1942
  3. United States v. Safety Car Heating & Lighting Co.Supreme Court of the United States · 1936

3Cited by9 opinions

  1. Fry v. CommissionerUnited States Tax Court · 1945
  2. Computing & Software, Inc. v. CommissionerUnited States Tax Court · 1976
  3. Aqualane Shores, Inc. v. CommissionerUnited States Tax Court · 1958
  4. Computing & Software, Inc. v. CommissionerUnited States Tax Court · 1976
  5. Fry v. CommissionerUnited States Tax Court · 1945

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

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API