Electric & Neon, Inc. v. Commissioner
United States Tax Court
1. The corporate petitioner constructed custom-made signs which it leased to customers. Lease durations varied from 1 to 10 years, the most common duration being 5 years. Leases were sometimes not renewed; when renewed, the rental rate was often substantially reduced. The signs were generally of no use to anyone but the original lessees.
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1. The corporate petitioner constructed custom-made signs which it leased to customers. Lease durations varied from 1 to 10 years, the most common duration being 5 years. Leases were sometimes not renewed; when renewed, the rental rate was often substantially reduced. The signs were generally of no use to anyone but the original lessees. Held: The costs of constructing the signs must be treated as capital expenditures, depreciable over the term of the original lease in each case. An adjustment under sec. 481, I.R.C. 1954, must be made with respect to the transitional year. 2. The individual…
1Opinion of the Court
Simpson, Judge:
In docket Nos. 1058-66 and 3259-70, tlie respondent determined the following deficiencies in the Federal income tax of the petitioner, Electric & Neon, Inc.:
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The respondent also determined an overassessment in the Federal income tax of such petitioner for the year ended September 30, 1967, in the amount of $2,404.34. In his answer to such, petitioner’s amended petition, the respondent alleged that if there is to be an adjustment under section 481,1.K.C. 1054,1 as was proposed in the amended petition, then the deficiency for the year ended September 30,1961, would…
2Cases cited43 opinions
- Beaver v. CommissionerUnited States Tax Court · 1970
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- Niles Bement Pond Co. v. United StatesSupreme Court of the United States · 1930
38 more not listed; retrieve them via the Exa API.
3Cited by199 opinions
- Hatfield v. CommissionerUnited States Tax Court · 1977
- Davis v. CommissionerUnited States Tax Court · 1983
- Waddell v. CommissionerUnited States Tax Court · 1986
- Paula Constr. Co. v. CommissionerUnited States Tax Court · 1972
- Crocker v. CommissionerUnited States Tax Court · 1989
194 more not listed; retrieve them via the Exa API.