Thompson & Folger Co. v. Commissioner
United States Tax Court
On its return for 1946, the petitioner claimed a deduction as ordinary and necessary expenses of amounts expended by it in leveling and grading hummocky land and swale, the drilling and equipping of a well to provide water for irrigation, and the installation of concrete pipe and other irrigation structures to carry and distribute the water over the land, all for the purpose of converting the land into such state that it could be cultivated.
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On its return for 1946, the petitioner claimed a deduction as ordinary and necessary expenses of amounts expended by it in leveling and grading hummocky land and swale, the drilling and equipping of a well to provide water for irrigation, and the installation of concrete pipe and other irrigation structures to carry and distribute the water over the land, all for the purpose of converting the land into such state that it could be cultivated. The respondent, in determining the deficiency herein, disallowed the deduction so claimed. Held, that the expenditures in question, being capital in…
1Opinion of the Court
OPINION.
Turner, Judge: The respondent determined deficiencies in income and excess profits taxes against petitioner as follows:
Year ' Income tax Excess profits tax
1944..... $4, 105. 53 ..
1945____-.... $6, 678. 11
1946_ 9, 313. 57 __
The question presented is whether the petitioner’s expenditures incurred in the leveling and grading of certain hummocky land and swale, the drilling and equipping of a well and the installation of pipes and other structures for the distribution of water over the land so as to convert the land to a state susceptible for cultivation are deductible as business…
2Cited by16 opinions
- Wilbur v. CommissionerUnited States Tax Court · 1964
- McBride v. CommissionerUnited States Tax Court · 1955
- Barham v. United StatesDistrict Court, M.D. Georgia · 1969
- Maple v. CommissionerUnited States Tax Court · 1968
- Robert J. Vinson, Ola M. Vinson, A. Starke Taylor, Jr. And Carolyn Taylor v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1980
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