Illinois Water Service Co. v. Commissioner
United States Tax Court
Petitioner, a subsidiary of a holding company, acquired its properties in 1927 from X corporation, a subsidiary of another holding company, which had acquired the same properties in 1926 from Y corporation.
Read the full summary
Petitioner, a subsidiary of a holding company, acquired its properties in 1927 from X corporation, a subsidiary of another holding company, which had acquired the same properties in 1926 from Y corporation. Until 1935 and 1936 petitioner took the view that the basis of the property for purposes of depreciation deductions was the same as the original basis to Y corporation under the theory that the basis was not increased as a result of the transfers of the property in 1926 and 1927. In this proceeding, involving 1935 and 1936, petitioner claimed that the property had acquired a new basis in…
1Opinion of the Court
HarRon, Judge:
The respondent determined a deficiency in income tax for the taxable years 1935 and 1936 in the respective amounts of $2,312.48 and $2,562.63.
The main question, involving the determination of annual depreciation allowance, is whether respondent erred in determining that petitioner is not entitled to a stepped-up basis for property known as the Freeport property. He determined that the basis to petitioner was $744,797.23 for 1935, and $749,008.41 for 1936. representing the cost basis of such property to the original owner of the property, the Freeport Water Co. adjusted for…
2Cases cited7 opinions
- Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
- LeTulle v. ScofieldSupreme Court of the United States · 1940
- Groman v. CommissionerSupreme Court of the United States · 1937
- John A. Nelson Co. v. HelveringSupreme Court of the United States · 1935
- Helvering v. BashfordSupreme Court of the United States · 1938
2 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
- Koppers Coal Co. v. CommissionerUnited States Tax Court · 1946
- Liddon v. CommissionerUnited States Tax Court · 1954
- Yoc Heating Corp. v. CommissionerUnited States Tax Court · 1973
- Southwell Combing Co. v. CommissionerUnited States Tax Court · 1958
- Kansas Sand & Concrete, Inc. v. CommissionerUnited States Tax Court · 1971
11 more not listed; retrieve them via the Exa API.