Hall v. Commissioner
United States Tax Court
1. Held, a contract as manager of a Texas mutual assessment insurance company assigned to petitioner has no reasonably ascertainable useful life and therefore the amount paid for the assignment is not subject to depreciation or amortization. 2. Held, further: The notice of deficiency issued by respondent is a valid notice.
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1. Held, a contract as manager of a Texas mutual assessment insurance company assigned to petitioner has no reasonably ascertainable useful life and therefore the amount paid for the assignment is not subject to depreciation or amortization. 2. Held, further: The notice of deficiency issued by respondent is a valid notice. Respondent did not make a second inspection of petitioner's books of account for the year 1963 as a result of a telephone conversation between the office auditor who previously having made an office audit of petitioner's 1963 income tax return was handling a claim for…
1Opinion of the Court
Millard H. Hall and Mettie Burma Hall, Petitioners v. Commissioner of Internal Revenue, Respondent
Hall v. Commissioner
Docket Nos. 1942-66, 1528-67
United States Tax Court
50 T.C. 186; 1968 U.S. Tax Ct. LEXIS 136;
April 30, 1968, Filed
Decisions will be entered under Rule 50.
1. Held, a contract as manager of a Texas mutual assessment insurance company assigned to petitioner has no reasonably ascertainable useful life and therefore the amount paid for the assignment is not subject to depreciation or amortization.
2. Held, further: The notice of deficiency issued by respondent is a valid notice.…
2Cases cited21 opinions
- Westinghouse Broadcasting Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1962
- Westinghouse Broadcasting Co. v. CommissionerUnited States Tax Court · 1961
- Nachman v. Commissioner of Internal Revenue. Tobias v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1951
- United States v. Charles G. Eidson, Jr.Court of Appeals for the Fifth Circuit · 1962
- Nachman v. CommissionerUnited States Tax Court · 1949
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