Legal Opinion
Pearson Hotel, Inc. v. United States
District Court, N.D. Illinois
Decided September 15, 1959No. Civ. A. Nos. 54 C 1952, 56 C 2062PublishedCited by 2 opinions
1Opinion of the Court
ROBSON, District Judge.
These two suits for refund of corporate income taxes involve different tax periods of the same taxpayer and concern the same legal issue. Plaintiff claims the right, under Section 113(a) (22) of the. Internal Revenue Code of 1939,1 to use its corporate predecessor’s basis for depreciation of its hotel property rather than the fair market value of said property at the time of its acquisition on foreclosure sale. This issue is in turn resolved by a determination of whether plaintiff acquired the property pursuant to a tax-free, court-approved plan of reorganization within…
2Cases cited9 opinions
- Northern Pacific Railway Co. v. BoydSupreme Court of the United States · 1913
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- Helvering v. Alabama Asphaltic Limestone Co.Supreme Court of the United States · 1942
- Palm Springs Holding Corp. v. CommissionerSupreme Court of the United States · 1942
- Mascot Stove Co. v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1941
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3Cited by2 opinions
- Northwestern Terra Cotta Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1961
- Ralphs Grocery Co. & Subsidiaries v. Comm'rUnited States Tax Court · 2011