Legal Opinion

Cameron Machine Co. v. Commissioner

United States Tax Court

Decided June 14, 1955No. Docket No. 39443Published

Held, that anticipatory expenditures in the total amount of $ 23,299.03 for replacement facilities paid out of petitioner's general funds, and prior to payment of award, do not qualify for nonrecognition of gain under section 112(f), 1939 Code.

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Held, that anticipatory expenditures in the total amount of $ 23,299.03 for replacement facilities paid out of petitioner's general funds, and prior to payment of award, do not qualify for nonrecognition of gain under section 112(f), 1939 Code. Held, further, (a) that amounts totaling $ 108,173.33 paid out for replacement facilities were traced to funds borrowed for that purpose; that the borrowed funds so applied were repaid out of the subsequent award; and that the amounts in question qualify for nonrecognition of gain under section 112 (f); and (b) that amounts totaling $ 27,698.63 paid…

1Opinion of the Court

Cameron Machine Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Cameron Machine Co. v. Commissioner

Docket No. 39443

United States Tax Court

24 T.C. 394; 1955 U.S. Tax Ct. LEXIS 172;

June 14, 1955, Filed

Decision will be entered under Rule 50.

Held, that anticipatory expenditures in the total amount of $ 23,299.03 for replacement facilities paid out of petitioner's general funds, and prior to payment of award, do not qualify for nonrecognition of gain under section 112(f), 1939 Code. Held, further, (a) that amounts totaling $ 108,173.33 paid out for replacement facilities were…

Also in this document: Dissent.

2Cases cited6 opinions

  1. Winter Realty & Const. Co. v. Commissioner of Int. Rev.Court of Appeals for the Second Circuit · 1945
  2. Bandes v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1934
  3. Twinboro Corp. v. CommissionerCourt of Appeals for the Second Circuit · 1945
  4. Wilmore SS Co. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1935
  5. Strauss v. CommissionerUnited States Tax Court · 1954

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