Wenzel v. Commissioner
United States Tax Court
In 1979 petitioners purchased a farm with an acreage allotment for the production of peanuts. Petitioners depreciated the allotment as an intangible asset for the taxable years 1982 through 1985. Held: Petitioners' allotment was not subject to depreciation. Held further: Petitioners are liable for the addition to tax for substantial understatement of income tax for the taxable year 1985.
1Opinion of the Court
FRED W. WENZEL AND MARY WENZEL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Wenzel v. Commissioner
Docket No. 29466-88
United States Tax Court
T.C. Memo 1991-166; 1991 Tax Ct. Memo LEXIS 185; 61 T.C.M. (CCH) 2396; T.C.M. (RIA) 91166;
April 10, 1991, Filed
Decision will be entered for the respondent.
In 1979 petitioners purchased a farm with an acreage allotment for the production of peanuts. Petitioners depreciated the allotment as an intangible asset for the taxable years 1982 through 1985. Held: Petitioners' allotment was not subject to depreciation. Held further: Petitioners are…
2Cases cited16 opinions
- Pallottini v. CommissionerUnited States Tax Court · 1988
- Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
- Toledo TV Cable Co. v. CommissionerUnited States Tax Court · 1971
- Pasadena City Lines, Inc. v. Commissioner (A)United States Tax Court · 1954
11 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Members of the Peanut Quota Holders Ass'n v. United StatesUnited States Court of Federal Claims · 2004