Hudson v. Commissioner
United States Tax Court
Petitioners paid sales taxes in acquiring farm machinery qualifying for the investment credit, and, in some instances, used machines were traded in and additional cash paid in acquiring the new machines. Petitioners computed basis for purposes of the investment tax credit by adding sales taxes paid to the price of the machinery acquired.
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Petitioners paid sales taxes in acquiring farm machinery qualifying for the investment credit, and, in some instances, used machines were traded in and additional cash paid in acquiring the new machines. Petitioners computed basis for purposes of the investment tax credit by adding sales taxes paid to the price of the machinery acquired. Held: Since taxpayers deducted the sales taxes currently rather than electing to capitalize them under sec. 266, I.R.C. 1954, the sales taxes are not included in basis. Additionally, where trade-ins are involved, petitioners' basis is not the list price of…
1Opinion of the Court
H. Lyle Hudson and Maxine Hudson, Petitioners v. Commissioner of Internal Revenue, Respondent
Hudson v. Commissioner
Docket No. 10665-76
United States Tax Court
77 T.C. 468; 1981 U.S. Tax Ct. LEXIS 73;
August 20, 1981, Filed
Decision will be entered under Rule 155.
Petitioners paid sales taxes in acquiring farm machinery qualifying for the investment credit, and, in some instances, used machines were traded in and additional cash paid in acquiring the new machines. Petitioners computed basis for purposes of the investment tax credit by adding sales taxes paid to the price of the machinery acquired.…
Also in this document: Concurrence.
2Cases cited6 opinions
- United Telecommunications, Inc. (Formerly United Utilities, Incorporated) v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1978
- Zuanich v. CommissionerUnited States Tax Court · 1981
- United Telecommunications, Inc. v. CommissionerUnited States Tax Court · 1975
- United Telecommunications, Inc. v. CommissionerUnited States Tax Court · 1977
- James G. Smyth, United States Collector of Internal Revenue v. John A. Sullivan, of the Estate of Emma L. Merritt, DeceasedCourt of Appeals for the Ninth Circuit · 1955
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