Legal Opinion

Spencer v. Commissioner

United States Tax Court

Decided February 9, 1998No. Tax Ct. Dkt. No. 16338-95; Docket No. 22465-95PublishedCited by 22 opinions

HELD, inter alia, upon redetermination of the original amortizable bases of property owned by P's S corporations, amortization must be calculated using the bases of the property as reduced by previously allowed amortization deductions.

1Opinion of the Court

Wells, Judge:

The instant cases were consolidated for purposes of trial, briefing, and opinion, and will hereinafter be referred to as the instant case. Respondent determined deficiencies in petitioners’ Federal income tax, additions to tax, and accuracy-related penalties as follows:

Bill L. and Patricia M. Spencer, docket No. 16338-95

Additions to tax Penalties Year Deficiency sec. 6651(a)(1) sec. 6662

1990 $696 - - - $139

1991 41,396 $10,335 8,279

1992 32,479 - - - 6,496

Joseph T. and Sheryl S. Schroeder, docket No. 22465-95

Additions to tax Penalties Year Deficiency sec. 6651(a)(1) sec. 6662

$12,298…

2Cases cited31 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Higgins v. SmithSupreme Court of the United States · 1940
  3. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  4. Wichita Term. El. Co. v. Commissioner of Int. R.Court of Appeals for the Tenth Circuit · 1947
  5. Burnet v. Sanford & Brooks Co.Supreme Court of the United States · 1931

26 more not listed; retrieve them via the Exa API.

3Cited by22 opinions

  1. William H. Maloof v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 2006
  2. Maloof v. Comm'rUnited States Tax Court · 2005
  3. Chapman Glen Ltd. v. CommissionerUnited States Tax Court · 2013
  4. UNITED STATES TAX COURT FRONTIER CHEVROLET CO. v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 2001
  5. O'Neal v. Comm'rUnited States Tax Court · 2016

17 more not listed; retrieve them via the Exa API.

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