Union Pacific Corp. v. Commissioner
United States Tax Court
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
- Moore v. CommissionerUnited States Tax Court · 1972
- Bailey v. CommissionerUnited States Tax Court · 1987
3Cited by17 opinions
- City of New York v. CommissionerUnited States Tax Court · 1994
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- Texaco Inc. v. CommissionerUnited States Tax Court · 1993
- Estate of Gillespie v. CommissionerUnited States Tax Court · 1994
- Allen v. Comm'rUnited States Tax Court · 2014
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