Legal Opinion

Frank J. Evans and Margueritte A. Evans v. Commissioner of Internal Revenue

Court of Appeals for the Ninth Circuit

Decided July 7, 1969No. 22509PublishedCited by 43 opinions

1Per curiam

The taxpayers purchased a trailer park and subsequently operated it. Stipulated portions of the purchase price represented the cost of four utility systems which had been installed for sewage disposal and for the distribution of electricity, gas, and water to those who rented space in the facility. The issue presented is whether the taxpayers are entitled to an investment credit (under sections 38, 46, and 48 of the Internal Revenue Code of 1954) for the cost of the four systems. The Tax Court held that the utility systems were not “Section 38 property” and did not qualify for the investment…

2Cases cited3 opinions

  1. Evans v. CommissionerUnited States Tax Court · 1967
  2. Mt. Mansfield Co. v. CommissionerUnited States Tax Court · 1968
  3. Mt. Mansfield Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969

3Cited by43 opinions

  1. Everhart v. CommissionerUnited States Tax Court · 1973
  2. Munford, Inc. v. CommissionerUnited States Tax Court · 1986
  3. Jake Z. Schrum Ruby E. Schrum Dannie L. Schrum Jeanette v. Schrum Donald L. Moore Judith A. Moore v. Commissioner of the Internal Revenue ServiceCourt of Appeals for the Fourth Circuit · 1994
  4. Grow v. CommissionerUnited States Tax Court · 1983
  5. Webb v. CommissionerUnited States Tax Court · 1977

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