Industrial & Agrigrowth Consulting Services, Inc. v. Commissioner
United States Tax Court
Petitioner deducted the cost of ornamental trees purchased during each of the years 1977 through 1982. Held: The purchase costs of the trees in issue are capital in nature and therefore are not currently deductible. Held further: Petitioners failed to establish that the trees in issue qualify as "young plants" under sec. 1.162-12(a), Income Tax Regs.
1Opinion of the Court
INDUSTRIAL & AGRIGROWTH CONSULTING SERVICES, INC., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Industrial & Agrigrowth Consulting Services, Inc. v. Commissioner
Docket Nos. 1373-85; 1374-85; 43176-85
United States Tax Court
T.C. Memo 1988-382; 1988 Tax Ct. Memo LEXIS 411; 55 T.C.M. (CCH) 1614; T.C.M. (RIA) 88382;
August 16, 1988.
Petitioner deducted the cost of ornamental trees purchased during each of the years 1977 through 1982. Held: The purchase costs of the trees in issue are capital in nature and therefore are not currently deductible. Held further: Petitioners…
2Cases cited16 opinions
- Tyler v. United StatesSupreme Court of the United States · 1930
- Nat Harrison Assoc., Inc. v. CommissionerUnited States Tax Court · 1964
- Riss v. CommissionerUnited States Tax Court · 1971
- Seligman v. CommissionerUnited States Tax Court · 1985
- Riss v. CommissionerUnited States Tax Court · 1971
11 more not listed; retrieve them via the Exa API.