Laglia v. Commissioner
United States Tax Court
Ps incurred expenses in connection with their jojoba plantation. They deducted and did not capitalize the expenses pursuant to sec. 278(b), I.R.C. 1954. Held: A jojoba plantation is not a "grove, orchard, or vineyard in which fruit or nuts are grown." Such expenses may therefore be deducted.
1Opinion of the Court
PARR, Judge:
Respondent determined that petitioners are hable for deficiences in income tax for the years 1981 and 1982 in the respective amounts of $7,930 and $5,783, together with additions to tax under section 6653(a)1 in the respective amounts of $396 and $289, an addition to tax under section 6661 for the year 1982 in the amount of $578, and additions to tax for 1981 and 1982 under section 6621(c), Tax Reform Act of 1986 (formerly section 6621(d)).2 Respondent determined that petitioners must capitalize farming expenses claimed on Schedule F for 1981 and 1982 in the respective amounts of…
2Cases cited13 opinions
- Crane v. CommissionerSupreme Court of the United States · 1947
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Commissioner v. EngleSupreme Court of the United States · 1984
- Commissioner v. Portland Cement Co. of UtahSupreme Court of the United States · 1981
- F. W. Woolworth Co. v. CommissionerUnited States Tax Court · 1970
8 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
- Estate of Wallace v. CommissionerUnited States Tax Court · 1990
- General Dynamics Corp. v. CommissionerUnited States Tax Court · 1997
- Estate of Howard v. CommissionerUnited States Tax Court · 1988
- Estate of Clayton v. CommissionerUnited States Tax Court · 1991
- Estate of Shelfer v. CommissionerUnited States Tax Court · 1994
18 more not listed; retrieve them via the Exa API.