American Twist Drill Co. v. Commissioner
United States Tax Court
Held, petitioner failed to file application for a necessity certificate for an amortization deduction under section 124 (a), Internal Revenue Code, for certain drill milling machines within six months after the beginning of construction thereof as required by section 124 (f) (3), Internal Revenue Code, and, hence, is not entitled to such deduction for the taxable year 1941.
1Opinion of the Court
OPINION.
Hill, Judge'.
The ultimate question for decision is whether petitioner filed application for the certificate prerequisite to an amortization deduction for the seven drill milling machines involved within the period of limitations provided by section 124 (f) (3) of the Internal Revenue Code. The answer to that queston hinges upon the interpretation and construction of the material part of such section, which reads as follows :
SEC. 124. AMORTIZATION DEDUCTION.
****** *(3) The certificate provided for in paragraph (1)1 shall have no effect unless an application therefor is filed before the…
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- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980