Legal Opinion

Fribourg Navigation Co. v. Commissioner

Supreme Court of the United States

Decided March 7, 1966No. 23PublishedCited by 131 opinions

1Opinion of the CourtChief Justice Warren

The question presented for determination is whether, as a matter of law, the sale of a depreciable asset for an amount in excess of its adjusted basis at the beginning of the year of sale bars deduction of depreciation for that year.

*274On December 21, 1955, the taxpayer, Fribourg Navigation Co., Inc., purchased the S. S. Joseph Feuer, a used Liberty ship, for $469,000. Prior to the acquisition, the taxpayer obtained a letter ruling from the Internal Revenue Service advising that the Service would accept straight-line depreciation of the ship over a useful economic life of three years, subject to…

2Cases cited28 opinions

  1. United States v. LudeySupreme Court of the United States · 1927
  2. Helvering v. WinmillSupreme Court of the United States · 1938
  3. Cammarano v. United StatesSupreme Court of the United States · 1959
  4. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
  5. Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943

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3Cited by131 opinions

  1. United States v. CorrellSupreme Court of the United States · 1967
  2. Securities & Exchange Commission v. SloanSupreme Court of the United States · 1978
  3. Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
  4. In Re Elmira Litho, Inc.United States Bankruptcy Court, S.D. New York · 1994
  5. United States v. Chicago, Burlington & Quincy RailroadSupreme Court of the United States · 1973

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