Broz v. Comm'r
United States Tax Court
Ps were shareholders in a wholly owned S corporation (S) engaged in providing wireless cellular service. The parties dispute the length in years of the recovery period that S must use to calculate its annual depreciation deduction for the wireless cellular assets. Wireless cellular assets include antenna support structures, cell site equipment and leased digital equipment.
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Ps were shareholders in a wholly owned S corporation (S) engaged in providing wireless cellular service. The parties dispute the length in years of the recovery period that S must use to calculate its annual depreciation deduction for the wireless cellular assets. Wireless cellular assets include antenna support structures, cell site equipment and leased digital equipment. Held: We apply the plain language of sec. 168, I.R.C., in interpreting classification issues of first impression. The plain language of Rev. Proc. 87-56, 1987-2 C.B. 674, the revenue procedure in effect for the years at…
1Opinion of the Court
ROBERT AND KIMBERLY BROZ, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Broz v. Comm'r
Docket No. 21629-06
United States Tax Court
137 T.C. 25; 2011 U.S. Tax Ct. LEXIS 35; 137 T.C. No. 3;
July 7, 2011, Filed
Ps were shareholders in a wholly owned S corporation (S) engaged in providing wireless cellular service. The parties dispute the length in years of the recovery period that S must use to calculate its annual depreciation deduction for the wireless cellular assets. Wireless cellular assets include antenna support structures, cell site equipment and leased digital equipment. Held:…
2Cases cited7 opinions
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Norwest Corp. v. Comm'rUnited States Tax Court · 1998
- Pacific Enters. & Subsidiaries v. CommissionerUnited States Tax Court · 1993
- Sprint Corp. v. CommissionerUnited States Tax Court · 1997
- Grinalds v. CommissionerUnited States Tax Court · 1993
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