Legal Opinion

Illinois Water Service Co. v. Commissioner

United States Tax Court

Decided December 24, 1943No. Docket No. 100404PublishedCited by 16 opinions

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.

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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

  1. Pinellas Ice & Cold Storage Co. v. CommissionerSupreme Court of the United States · 1933
  2. LeTulle v. ScofieldSupreme Court of the United States · 1940
  3. Groman v. CommissionerSupreme Court of the United States · 1937
  4. John A. Nelson Co. v. HelveringSupreme Court of the United States · 1935
  5. Helvering v. BashfordSupreme Court of the United States · 1938

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

3Cited by16 opinions

  1. Koppers Coal Co. v. CommissionerUnited States Tax Court · 1946
  2. Liddon v. CommissionerUnited States Tax Court · 1954
  3. Yoc Heating Corp. v. CommissionerUnited States Tax Court · 1973
  4. Southwell Combing Co. v. CommissionerUnited States Tax Court · 1958
  5. Kansas Sand & Concrete, Inc. v. CommissionerUnited States Tax Court · 1971

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

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