Legal Opinion

Matson Navigation Co. v. Commissioner

United States Tax Court

Decided March 16, 1977No. Docket Nos. 1625-74, 1626-74PublishedCited by 26 opinions

Rule 121, Tax Court Rules of Practice and Procedure. -- P moved for summary judgment, asserting that its depreciation deductions for the taxable years 1965 through 1969 were allowable in accordance with Rev. Procs. 62-21, 1962-2 C.B. 418, and 65-13, 1965-1 C.B. 759, or in the alternative, that if adjustments are to be made in its depreciation deductions, the Court can and should decide in accordance with such revenue procedures the amount of such adjustments.

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Rule 121, Tax Court Rules of Practice and Procedure. -- P moved for summary judgment, asserting that its depreciation deductions for the taxable years 1965 through 1969 were allowable in accordance with Rev. Procs. 62-21, 1962-2 C.B. 418, and 65-13, 1965-1 C.B. 759, or in the alternative, that if adjustments are to be made in its depreciation deductions, the Court can and should decide in accordance with such revenue procedures the amount of such adjustments. Held, motion granted in part and denied in part; Rev. Procs. 62-21, 65-13, and 68-27, 1968-2 C.B. 911, interpreted and applied.

1Opinion of the Court

OPINION

Simpson, Judge:

The petitioners have made a timely motion for partial summary judgment pursuant to Rule 121, Tax Court Rules of Practice and Procedure. The issues raised by this motion are: (1) Whether Matson Navigation Co. (Matson) can justify its claimed depreciation deductions for its water transportation equipment for the taxable years 1965 through 1969 on the basis of Rev. Proc. 62-21, 1962-2 C.B. 418,1 as modified by Rev. Proc. 65-13, 1965-1 C.B. 759; (2) whether, if Matson cannot justify its claimed depreciation deductions for such years on the basis of such revenue procedures,…

2Cases cited8 opinions

  1. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
  2. Shiosaki v. CommissionerUnited States Tax Court · 1974
  3. Casey v. CommissionerUnited States Tax Court · 1962
  4. Hoeme v. CommissionerUnited States Tax Court · 1974
  5. Wooten v. CommissionerUnited States Tax Court · 1949

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

3Cited by26 opinions

  1. Espinoza v. CommissionerUnited States Tax Court · 1982
  2. Boyd Gaming Corp. v. CommissionerUnited States Tax Court · 1996
  3. Carland, Inc. v. CommissionerUnited States Tax Court · 1988
  4. Galanis v. CommissionerUnited States Tax Court · 1989
  5. Sorrell v. CommissionerUnited States Tax Court · 1987

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

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