Trentadue v. Comm'r
United States Tax Court
Ps depreciated trellising, drip irrigation systems, and a well as farm machinery or equipment, in connection with their farming activity of growing wine grapes. R determined that such property would have a longer class life and be depreciable as permanent improvements to land. Held: The trellising was properly classified as farm machinery or equipment, and the irrigation systems and well should be classified as land improvements.
1Opinion of the Court
LEO AND EVELYN TRENTADUE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Trentadue v. Comm'r
No. 3510-04
United States Tax Court
128 T.C. 91; 2007 U.S. Tax Ct. LEXIS 8; 128 T.C. No. 8;
April 3, 2007, Filed
The court held that the trellising was not a permanent improvement to the real property and, accordingly, was a 10-year class asset. The well and drip irrigation systems were permanent improvements to the real property. Accordingly, the Commissioner's adjustments were sustained with respect to the irrigation systems and the well. Conversely, the Commissioner's determination with…
2Cases cited9 opinions
- Whiteco Indus. v. Comm'rUnited States Tax Court · 1975
- Consolidated Freightways, Inc. & Affiliates v. CommissionerUnited States Tax Court · 1980
- Kimmelman v. CommissionerUnited States Tax Court · 1979
- The Kramertown Company, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1974
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1997
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