Legal Opinion

Wenzel v. Commissioner

United States Tax Court

Decided April 10, 1991No. Docket No. 29466-88UnpublishedCited by 1 opinion

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

  1. Pallottini v. CommissionerUnited States Tax Court · 1988
  2. Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
  3. Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
  4. Toledo TV Cable Co. v. CommissionerUnited States Tax Court · 1971
  5. 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

  1. Members of the Peanut Quota Holders Ass'n v. United StatesUnited States Court of Federal Claims · 2004

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

Powered by the Exa API