Fribourg Navigation Company, Inc. v. Commissioner of Internal Revenue

J. JOSEPH SMITH, Circuit Judge,

The sole issue presented by this appeal is whether a taxpayer is entitled to a depreciation deduction for the year in which a depreciable asset is sold at more than its depreciated cost. The Tax Court sustained the Commissioner’s dis-allowance of the deduction, and the taxpayer has appealed to this court. We agree with the Tax Court’s determination and affirm the judgment. J

The taxpayer, Fribourg Navigation Co., operated two cargo ships in foreign commerce. One of these was the S. S. Feuer, a Liberty ship purchased in December of 1955 for $469,000. Just prior to…