Seminole Rock & Sand Co. v. Commissioner
United States Tax Court
1. The controlling stockholder of petitioner which was engaged in the rock and sand business, formed a partnership which furnished technical and management services to petitioner and other enterprises of which the stockholder had control. Held, respondent erred in allocating to petitioner part of the gross income and deductions of the partnership under section 45, Internal Revenue Code. 2. Held, further, petitioner was entitled to a loss for abandonment of an asphalt plant.
1Opinion of the Court
Tietjens, Judge:
Petitioner asks a redetermination of a deficiency in income tax for 1943 of $21,500.37.
Two issues are presented for decision: (1) Was the allocation to petitioner of a portion of the gross income and deductions of Pratt, Lassiter & Watkins, a partnership, proper; and (2) was petitioner entitled to a claimed deduction for loss due to abandonment of an asphalt plant.
FINDINGS OF FACT.
The petitioner (hereinafter called the taxpayer) is a Florida corporation, organized in 1933, with its headquarters in Miami, Florida, immediately south of the International Airport. During 1943 it…
2Cases cited3 opinions
- Commissioner of Internal Revenue v. Chelsea Products, IncCourt of Appeals for the Third Circuit · 1952
- Commissioner of Internal Revenue v. Boston Elevated Ry. CoCourt of Appeals for the First Circuit · 1952
- Boston Elevated Railway Co. v. CommissionerUnited States Tax Court · 1951
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- Chicago & N. W. R. Co. v. CommissionerUnited States Tax Court · 1958
- Hummel v. United StatesDistrict Court, N.D. California · 1963
- Interior Securities Corp. v. CommissionerUnited States Tax Court · 1962
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