Legal Opinion

Union Pacific Corp. v. Commissioner

United States Tax Court

Decided July 18, 1988No. Docket No. 24152-81PublishedCited by 17 opinions

Petitioner operated rail-test cars to detect defective track which was then replaced. Held, petitioner is not entitled to an investment tax credit in respect of the operating costs of such cars. Petitioner made mobile homes available rent-free to certain of its employees responsible for sections of track in remote areas. Held, such mobile homes constitute "lodging" with the result that petitioner is not entitled to an investment credit for its investment in such homes.

1Opinion of the Court

OPINION

TANNENWALD, Judge:

Respondent determined the following deficiencies in petitioner’s Federal income tax:

Year Deficiency

1975 . $4,072,046

1976. 5,509,231

1977. 45,869,744

After concessions by the parties, the issues for decision are whether petitioner is entitled to an investment tax credit for the costs of operating equipment used to detect flaws in railroad track, and whether petitioner is entitled to an investment tax credit for investments in mobile homes used to house certain employees.

The facts were fully stipulated. The stipulation of facts and attached exhibits are incorporated…

2Cases cited2 opinions

  1. Moore v. CommissionerUnited States Tax Court · 1972
  2. Bailey v. CommissionerUnited States Tax Court · 1987

3Cited by17 opinions

  1. City of New York v. CommissionerUnited States Tax Court · 1994
  2. Rome I, Ltd. v. CommissionerUnited States Tax Court · 1991
  3. Texaco Inc. v. CommissionerUnited States Tax Court · 1993
  4. Estate of Gillespie v. CommissionerUnited States Tax Court · 1994
  5. Allen v. Comm'rUnited States Tax Court · 2014

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