Panhandle State Bank v. Commissioner
United States Tax Court
Held, at the time of purchase, petitioner did not intend ultimately to demolish the building situated on the property purchased by petitioner in 1952 and an allocation of the purchase price between the building and the land was proper. Petitioner's purpose in subsequently removing the building was due to a change in circumstances that made use of the building for a drive-in banking area and for a bookkeeping department economically unfeasible.
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Held, at the time of purchase, petitioner did not intend ultimately to demolish the building situated on the property purchased by petitioner in 1952 and an allocation of the purchase price between the building and the land was proper. Petitioner's purpose in subsequently removing the building was due to a change in circumstances that made use of the building for a drive-in banking area and for a bookkeeping department economically unfeasible. Held, further, the value allocated by petitioner to the building for purposes of depreciation was reasonable. The undepreciated cost of the building…
1Opinion of the Court
OPINION.
Black, Judge:
Petitioner claims a deduction in the year 1957 in the amount of $12,133.89 as a loss due to the demolition of a building in that year. Such amount represents the undepreciated cost of said building at that time, less amount received for salvage. Petitioner had purchased a piece of property in 1952 with a building situated thereon. Of the purchase price of $40,000, $25,500 was allocated to the building and the remainder was allocated to the land. From the date of purchase to the date of demolition, petitioner made improvements and repairs to the building totaling $5,689.43…
2Cases cited4 opinions
- Chesbro v. CommissionerUnited States Tax Court · 1953
- Lynchburg Nat'l Bank & Trust Co. v. CommissionerUnited States Tax Court · 1953
- Lynchburg Nat. Bank & Trust Co. v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1953
- Heyman v. CommissionerUnited States Tax Court · 1946
3Cited by7 opinions
- Nash v. CommissionerUnited States Tax Court · 1973
- McBride v. Commissioner (A)United States Tax Court · 1968
- Meyer v. United StatesDistrict Court, D. Massachusetts · 1965
- The Montgomery Co. v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1964
- McBride v. Commissioner (A)United States Tax Court · 1968
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