Agro-Jal Farming Enters. v. Commissioner
United States Tax Court
P--a farming corporation--deducted the cost of various field-packing materials for the year in which it bought them. R contends that under IRC section 464 and 26 CFR section 1.162-3 P may deduct the cost of those materials only for the year in which P uses them. Held: The class of items described under section 464 as "feed, seed, fertilizer, or other similar farm supplies," does not include packing materials as "similar farm supplies."
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P--a farming corporation--deducted the cost of various field-packing materials for the year in which it bought them. R contends that under IRC section 464 and 26 CFR section 1.162-3 P may deduct the cost of those materials only for the year in which P uses them. Held: The class of items described under section 464 as "feed, seed, fertilizer, or other similar farm supplies," does not include packing materials as "similar farm supplies." Held, further, the "provided that" clause of section 1.162-3 for the years at issue means that the cost of materials and supplies must be deducted as the items…
1Opinion of the Court
AGRO-JAL FARMING ENTERPRISES, INC., ET AL.,1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Agro-Jal Farming Enters. v. Commissioner
Docket Nos. 15103-10, 3924-11.
United States Tax Court
145 T.C. 145; 2015 U.S. Tax Ct. LEXIS 33; 145 T.C. No. 5;
July 30, 2015, Filed
An appropriate order will be issued granting petitioners' motion and denying respondent's motion.
P--a farming corporation--deducted the cost of various field-packing materials for the year in which it bought them. R contends that under IRC section 464 and 26 CFR section 1.162-3 P may deduct the cost of those materials only…
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- United States v. CattoSupreme Court of the United States · 1966
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