Legal Opinion

St. Louis Mallaeable Casting Co. v. Commissioner

United States Board of Tax Appeals

Decided November 15, 1927No. Docket Nos. 5490, 15168PublishedCited by 5 opinions

1. Fair market value of patents and patterns for purpose of the deduction for exhaustion, wear and tear determined. 2. Cost of assets to be used for depreciation and invested capital determined.

1Opinion of the Court

*115OPINION*

Littleton:

The first issue is the value at March 1, 1913, of the patterns owned by the petitioner on that date. As set forth in the findings of fact, a value has been assigned to these patterns at March 1, 1913, in the report of the appraisal company which purported to be the reconstruction cost of the patterns then on hand, less its estimate of depreciation sustained prior to that date.

The so-called retrospective appraisal of patterns was at best a rough segregation of the working hours and material applicable to patterns as shown by the petitioner’s records into working hours and…

2Cited by5 opinions

  1. Hillcone S.S. Co. v. CommissionerUnited States Tax Court · 1963
  2. Hardin v. CommissionerUnited States Tax Court · 1973
  3. New York City Omnibus Corp. v. CommissionerUnited States Tax Court · 1948
  4. St. Louis Mallaeable Casting Co. v. CommissionerUnited States Board of Tax Appeals · 1927
  5. St. Louis Malleable Casting Co. v. CommissionerUnited States Board of Tax Appeals · 1931

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