Legal Opinion

Trailmont Park, Inc. v. Commissioner

United States Tax Court

Decided August 25, 1971No. Docket No. 4324-70 SCUnpublished

Petitioner incurred approximately $190,000 improvement costs in the development and construction of a mobile home park. It assigned a useful life of 15 years to these improvements.

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Petitioner incurred approximately $190,000 improvement costs in the development and construction of a mobile home park. It assigned a useful life of 15 years to these improvements. In 1967 it claimed $8,483.51 of this amount as depreciation and $12,816.45 was claimed as depreciation in 1968. Respondent determined that a portion of these costs, $1,607.66 in 1967 and $2,410.59 in 1968, were attributable to the cost of clearing, grading,e, nondepreciable. terracing, and landscaping the land and, therefore, nondepreciable. Held: These costs were an integral part of the developemnt and…

1Opinion of the Court

Trailmont Park, Inc. v. Commissioner.

Trailmont Park, Inc. v. Commissioner

Docket No. 4324-70 SC.

United States Tax Court

T.C. Memo 1971-212; 1971 Tax Ct. Memo LEXIS 117; 30 T.C.M. (CCH) 871; T.C.M. (RIA) 71212;

August 25, 1971, filed

Petitioner incurred approximately $190,000 improvement costs in the development and construction of a mobile home park. It assigned a useful life of 15 years to these improvements. In 1967 it claimed $8,483.51 of this amount as depreciation and $12,816.45 was claimed as depreciation in 1968. Respondent determined that a portion of these costs, $1,607.66 in 1967 and…

2Cases cited10 opinions

  1. Southern Natural Gas Company v. The United StatesUnited States Court of Claims · 1969
  2. Algernon Blair, Inc. v. CommissionerUnited States Tax Court · 1958
  3. Norfolk Shipbuilding and Drydock Corp. v. United StatesDistrict Court, E.D. Virginia · 1971
  4. Alabama-Georgia Syrup Co. v. CommissionerUnited States Tax Court · 1961
  5. L. B. Whitfield, Jr., and Virginia G. Whitfield v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1962

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