Legal Opinion

Cameron v. Commissioner

United States Board of Tax Appeals

Decided September 19, 1927No. Docket No. 9686PublishedCited by 17 opinions

1. When in 1920 one partnership is succeeded by another partnership and the interests of the members continue substantially as before with the exception of a gift by one of the partners of his partnership interest to a new partner and a change in the distributive shares of the partnership income, no new basis for computing the allowance for exhaustion, wear and tear to the partnership arises. 2. The March 1, 1913, value of depreciable assets determined upon the basis of cost…

Read the full summary

1. When in 1920 one partnership is succeeded by another partnership and the interests of the members continue substantially as before with the exception of a gift by one of the partners of his partnership interest to a new partner and a change in the distributive shares of the partnership income, no new basis for computing the allowance for exhaustion, wear and tear to the partnership arises. 2. The March 1, 1913, value of depreciable assets determined upon the basis of cost less accrued depreciation instead of upon the basis of a retrospective appraisal made in 1926 of cost of reproduction…

1Opinion of the Court

*124OPINION.

Littleton :

The primary error assigned in this proceeding is the failure of the Commissioner to allow adequate depreciation for the years on appeal.

As the basis for this claim, the petitioners contend, first, that since the partnership which was formed in 1891 was dissolved and a new partnership came into existence on January 1, 1920, when A. W. Cameron was admitted to membership, there should be a revaluation of the assets of the partnership on January 1, 1920, for depreciation purposes in determining the distributive income of the partnership.

Granting that there was a new partnership…

2Cases cited3 opinions

  1. United States v. LudeySupreme Court of the United States · 1927
  2. United States v. CoulbyCourt of Appeals for the Sixth Circuit · 1919
  3. United States v. CoulbyDistrict Court, N.D. Ohio · 1918

3Cited by17 opinions

  1. Firemen's Ins. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  2. First Northwest Industries, Inc. v. CommissionerUnited States Tax Court · 1978
  3. Baltimore & O. R. Co. v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Shaffer v. CommissionerUnited States Board of Tax Appeals · 1934
  5. A. H. Morse Co. v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1953

12 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API