Amfac, Inc. v. Commissioner
United States Tax Court
Puna expended certain sums in priming three fields for the cultivation of sugar cane. Held, such amounts are not deductible under sec. 175 as expenditures incurred for the purpose of soil or water conservation.
1Opinion of the Court
Sterrett, Judge:
Respondent, on May 16, 1975, issued a statutory notice in which he determined a deficiency of $170,315 in petitioner’s corporate income tax. The issue presented for our determination is whether petitioner may deduct under section 175(a), I.R.C. 1954, expenditures, otherwise characterized as capital in nature, incurred in 1969 to improve three fields.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts, together with the exhibits attached thereto, are incorporated herein by this reference.
Petitioner AMFAC, Inc., is a corporation with…
2Cases cited5 opinions
- A. Duda & Sons, Inc. v. United StatesCourt of Appeals for the Fifth Circuit · 1977
- Behring v. CommissionerUnited States Tax Court · 1959
- Collingwood v. CommissionerUnited States Tax Court · 1953
- Estate of Straughn v. CommissionerUnited States Tax Court · 1970
- A. Duda & Sons, Inc. v. United StatesDistrict Court, M.D. Florida · 1974
3Cited by4 opinions
- Amfac, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1980
- Amfac, Inc. v. CommissionerUnited States Tax Court · 1978
- Sherwood v. CommissionerUnited States Tax Court · 1988
- Tharp v. CommissionerUnited States Tax Court · 1989