Chesapeake & O. R. Co. v. Commissioner
United States Tax Court
1. T Co., a railroad, had chosen in the past and continued during the taxable years to use the retirement-replacement-betterment (RRB) method of accounting in respect of those assets, such as rail, ties, and ballast, which comprised its track structure. Under the RRB method, T was not entitled to deduct a ratable allowance for depreciation in respect of these assets as it would have had it chosen the straight-line method of depreciation.
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1. T Co., a railroad, had chosen in the past and continued during the taxable years to use the retirement-replacement-betterment (RRB) method of accounting in respect of those assets, such as rail, ties, and ballast, which comprised its track structure. Under the RRB method, T was not entitled to deduct a ratable allowance for depreciation in respect of these assets as it would have had it chosen the straight-line method of depreciation. Instead, T maintained the entire initial cost of its track structure, plus any betterments thereto, in its capital accounts until its final retirement, at…
1Opinion of the Court
Raum, Judge:
The Commissioner determined deficiencies in petitioner’s1 Federal corporate income taxes for the years 1954 through 1963, and petitioner, by its original and amended petitions, has claimed overpayments in each of those years with the exception of 1963. The respective amounts of the determined deficiencies and the claimed overpayments are as follows:
Docket No. Calendar year Deficiency Overpayment (per amended petitions)
5904-70 _ 1954 $1,316,049.31 $4,510,178.49
1955 5,861,634.16 2,281,363.35
1956 2,368,983.46 5,622,512.30
1957 789,708.90 4,561,570.11
1958 4,315,981.24 3,809,908.98
1959…
2Cases cited37 opinions
- United States v. LudeySupreme Court of the United States · 1927
- Bartels v. BirminghamSupreme Court of the United States · 1947
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Helvering v. New York Trust Co.Supreme Court of the United States · 1934
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
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3Cited by35 opinions
- Southern Pacific Transp. Co. v. CommissionerUnited States Tax Court · 1980
- Burlington Northern Inc. v. United StatesUnited States Court of Claims · 1982
- Louisville and Nashville Railroad Company v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1981
- Louisville & N. R. Co. v. CommissionerUnited States Tax Court · 1976
- Kansas City S. R. Co. v. CommissionerUnited States Tax Court · 1981
30 more not listed; retrieve them via the Exa API.