Matson Navigation Co. v. Commissioner
United States Tax Court
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
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