Harrah v. Commissioner
United States Tax Court
1. Petitioners' transferor was engaged in the construction of sawmill plants and equipment which it sold in the ordinary course of its business. It also engaged in experimental work. On its own initiative it undertook the construction of an experimental portable sawmill to determine the feasibility of including such mill in its lines. It contemplated operating the mill for test purposes itself.
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1. Petitioners' transferor was engaged in the construction of sawmill plants and equipment which it sold in the ordinary course of its business. It also engaged in experimental work. On its own initiative it undertook the construction of an experimental portable sawmill to determine the feasibility of including such mill in its lines. It contemplated operating the mill for test purposes itself. When the mill was nearly completed, it was approached by an individual interested in purchasing it. His initial offer to purchase was refused because the worth of the mill was then unknown.…
1Opinion of the Court
TietjeNS, Judge:
These proceedings involve deficiencies in income and excess profits tax determined due from petitioners as transferees of Harrah Bros., Inc., for the taxable periods set forth below.
fiscal year ended Tax Deficiency
Mar. 31,1952 Income_$8,606.43
Nov. 20, 1952 Income and excess profits- 22,452.12
While conceding their liability as transferees, petitioners contest the deficiencies determined against their transferor by the Commissioner.
The issues are: (1) Whether a sawmill constructed by Harrah Bros., Inc., constituted property used in its trade or business within the meaning of…
2Cases cited8 opinions
- MAULDIN v. COMMISSIONER OF INTERNAL REVENUE (Two Cases)Court of Appeals for the Tenth Circuit · 1952
- Rollingwood Corp. v. Commissioner of Internal Revenue. Bohannon v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1951
- Mauldin v. CommissionerUnited States Tax Court · 1951
- Gilken Corporation v. Commissioner of Internal Rev.Court of Appeals for the Sixth Circuit · 1949
- Gilken Corp. v. CommissionerUnited States Tax Court · 1948
3 more not listed; retrieve them via the Exa API.
3Cited by23 opinions
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- American Can Co. v. CommissionerUnited States Tax Court · 1961
- Hollywood Baseball Ass'n v. CommissionerUnited States Tax Court · 1964
- Municipal Bond Corp. v. CommissionerUnited States Tax Court · 1966
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