Loda Poultry Co. v. Commissioner
United States Tax Court
P, a corporation, is engaged in the business of selling chickens and wholesaling meats and poultry. P also supplies a related corporation which owns and operates Kentucky Fried Chicken restaurants. P purchased an asset approximately 10,283 square feet in size. The asset has a concrete base with prefabricated modular foam panels.
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P, a corporation, is engaged in the business of selling chickens and wholesaling meats and poultry. P also supplies a related corporation which owns and operates Kentucky Fried Chicken restaurants. P purchased an asset approximately 10,283 square feet in size. The asset has a concrete base with prefabricated modular foam panels. The asset consists of air-cooled condensers and a commercial engine which provide refrigeration, and five separate refrigerated compartments: (1) A loading area; (2) a zero-degree compartment; (3) a 28-degree compartment; (4) a 32-degree compartment; and (5) a…
1Opinion of the Court
OPINION
DRENNEN, Judge-.
This case was assigned to and heard by Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7456(d)1 (redesignated as section 7443A(b) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq.2 After review of the record, we agree with and adopt his opinion which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
PANUTHOS, Special Trial Judge: Respondent determined a deficiency in petitioner’s Federal income tax in the amount of $14,718 for the taxable year ended January 31, 1980.
The issue for decision…
2Cases cited19 opinions
- United States v. CorrellSupreme Court of the United States · 1967
- Commissioner v. StidgerSupreme Court of the United States · 1967
- Catron v. CommissionerUnited States Tax Court · 1968
- Central Citrus Co. v. CommissionerUnited States Tax Court · 1972
- Consolidated Freightways, Inc. & Affiliates v. CommissionerUnited States Tax Court · 1980
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3Cited by13 opinions
- Vail Assocs. v. CommissionerUnited States Tax Court · 1987
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- Texas Instruments v. CommissionerUnited States Tax Court · 1992
- L & B Corp. v. CommissionerCourt of Appeals for the Eighth Circuit · 1988
- L & B Corporation, a Nebraska Corporation v. Commissioner of Internal Revenue, Larry A. Larsen and Betty J. Larsen v. Commissioner of Internal Revenue, Estate of Howard C. Larsen, Deceased, Maxine J. Larsen, and Maxine J. Larsen v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1988
8 more not listed; retrieve them via the Exa API.