Walker-Scott Corp. v. Commissioner
United States Tax Court
Held, in computing the percentage increase under section 444(b)(3), I.R.C. 1939, the basis, unadjusted, of petitioner's total facilities on the applicable dates should be computed without including the amounts of the lessors' bases, unadjusted, of the real property under lease to petitioner on such dates.
1Opinion of the Court
OPINION.
Van Fossan, Judge:
Respondent determined deficiencies in petitioner’s income and excess profits taxes as follows:
[[Image here]]
Petitioner assigned as errors the respondent’s determination of deficiencies in income taxes for the fiscal year ended January 31,1953, and in income and excess profits taxes for the fiscal year ended J anuary 31, 1954. The issue as ultimately stated by the parties is whether petitioner qualifies for relief under paragraph (b) (3) of section 444 of the Internal Revenue Code of 1939.1
All of the facts are stipulated by written agreement and are adopted and…
2Cases cited1 opinion
- Copco Steel & Engineering Co. v. CommissionerUnited States Tax Court · 1958
3Cited by5 opinions
- Kennedy v. CommissionerUnited States Tax Court · 1979
- Anaya v. CommissionerUnited States Tax Court · 1991
- Kennedy v. CommissionerUnited States Tax Court · 1979
- Pickering v. CommissionerUnited States Tax Court · 1979
- Walker-Scott Corp. v. CommissionerUnited States Tax Court · 1960