Legal Opinion
Estate of Walling v. Commissioner
Court of Appeals for the Third Circuit
Decided February 8, 1967No. 15805PublishedCited by 11 opinions
1Opinion of the Court
OPINION OF THE COURT
STALEY, Chief Judge.
This petition for review of a decision of the Tax. Court requires us to decide whether certain amounts expended by taxpayers were deductible as “repairs” under § 162(a) of the Internal Revenue Code of 1954, 26 U.S.C. § 162(a).1 The *192Tax Court held that the repairs were incidental to the transfer of the capital assets on which they were made and were, therefore, capital in nature, resulting in a determination of a deficiency in taxpayers’ return for the year of 1957.
In 1957, taxpayers, ,Ritner K. Walling 2 and Margaret C. Walling, his wife, were engaged…
2Cases cited17 opinions
- McDonald v. CommissionerSupreme Court of the United States · 1944
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
- National Securities Corp. v. Com'r of Internal RevenueCourt of Appeals for the Third Circuit · 1943
- Central Cuba Sugar Co. v. Commissioner of Internal Revenue. Commissioner of Internal Revenue v. Central Cuba Sugar CoCourt of Appeals for the Second Circuit · 1952
- Portland Oil Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1940
12 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Foster v. Comm'rUnited States Tax Court · 1983
- Dominion Resources, Incorporated v. United StatesCourt of Appeals for the Fourth Circuit · 2000
- Jerome S. Moss, Sandra Moss, Sharon M. Alesia, Herb Alpert, and Lani Alpert v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1987
- Hempt Bros., Inc. v. United StatesDistrict Court, M.D. Pennsylvania · 1973
- Norwest Corp. v. Comm'rUnited States Tax Court · 1997
6 more not listed; retrieve them via the Exa API.