Munford, Inc. v. Commissioner
United States Tax Court
During its taxable year ended Dec. 30, 1976, petitioner placed in service an addition to a refrigerated facility for the storage of frozen food products. The addition comprised a 3,900 square foot truck loading platform, a 1,030-square-foot rail loading platform and a 34,650-square-foot refrigerated area.
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During its taxable year ended Dec. 30, 1976, petitioner placed in service an addition to a refrigerated facility for the storage of frozen food products. The addition comprised a 3,900 square foot truck loading platform, a 1,030-square-foot rail loading platform and a 34,650-square-foot refrigerated area. Petitioner sought an investment tax credit under sec. 38, I.R.C. 1954, with respect to costs relating to the addition, contending that the structure constitutes tangible personal property under sec. 48(a)(1)(A). Respondent allowed the credit only with respect to certain refrigeration system…
1Opinion of the Court
Fay, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax as follows:
Taxable year ended— Deficiency
Jan. 3, 1974. $50,343
Jan. 2, 1975. 48,831
Jan. 1, 1976. 445,755
After concessions, the issues are (1) whether petitioner is entitled to an investment tax credit under section 381 with respect to an addition to a refrigerated storage facility to an extent greater than allowed by respondent, and (2) whether petitioner is entitled to depreciate the addition to the refrigerated storage facility using the 200-percent declining balance method of depreciation under section…
2Cases cited36 opinions
- United States v. ScovilSupreme Court of the United States · 1955
- Catron v. CommissionerUnited States Tax Court · 1968
- Woods Inv. Co. v. CommissionerUnited States Tax Court · 1985
- Evans v. CommissionerUnited States Tax Court · 1967
- Whiteco Indus. v. Comm'rUnited States Tax Court · 1975
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