Haspel v. Commissioner
United States Tax Court
Plaza Inn and its predecessors wanted to erect a hotel. They hired a firm of architects to design the entire building. After the foundation had been constructed, the plans for the superstructure, as designed by the original architects, were abandoned as too costly. A second firm of architects designed a different superstructure to be constructed upon the existing foundation; this second superstructure was eventually built.
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Plaza Inn and its predecessors wanted to erect a hotel. They hired a firm of architects to design the entire building. After the foundation had been constructed, the plans for the superstructure, as designed by the original architects, were abandoned as too costly. A second firm of architects designed a different superstructure to be constructed upon the existing foundation; this second superstructure was eventually built. Held, the petitioners are not entitled to an abandonment loss under the provisions of sec. 165(a) for the plans which were rejected, since the original architects' plans…
1Opinion of the Court
Sterrett, Judge:
The respondent determined the following deficiencies in the petitioners’ Federal income tax:
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The issues we must decide are as follows:(1) Whether the partnership, Plaza Inn, abandoned certain architectural and interior design plans thereby making the expenses incurred in the production of those plans deductible under the provisions of section 165,I.R.C. 1954.2(2) If such abandonment took place did it occur prior to February 16,1966, when the plans belonged to another entity.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of…
2Cases cited10 opinions
- Galt v. CommissionerUnited States Tax Court · 1953
- Coors Porcelain Co. v. CommissionerUnited States Tax Court · 1969
- Driscoll v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1945
- Burke v. CommissionerUnited States Tax Court · 1959
- Stanley Burke v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
5 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- John E. Rogers & Frances L. Rogers v. CommissionerUnited States Tax Court · 2018
- Clayton v. CommissionerUnited States Tax Court · 1981
- Energy Resources Ltd. Partnership v. CommissionerUnited States Tax Court · 1992
- Finley v. CommissionerUnited States Tax Court · 1974
- Haspel v. CommissionerUnited States Tax Court · 1974
2 more not listed; retrieve them via the Exa API.