Legal Opinion

Hub City Foods, Inc. v. Commissioner

United States Tax Court

Decided February 18, 1988No. Docket No. 6414-86Published

Petitioner constructed and placed in service a freezer facility and claimed an investment credit with respect thereto under sec. 38, I.R.C. 1954. Held, petitioner is not entitled to an investment credit with respect to the freezer facility under sec. 38, I.R.C. 1954, because the freezer facility does not constitute "other tangible property * * * used as an integral part of * * * furnishing transportation" within the meaning of sec. 48(a)(1)(B)(i), I.R.C. 1954.

1Opinion of the Court

Hub City Foods, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Hub City Foods, Inc. v. Commissioner

Docket No. 6414-86

United States Tax Court

90 T.C. 297; 1988 U.S. Tax Ct. LEXIS 23; 90 T.C. No. 23;

February 18, 1988. February 18, 1988, Filed

Decision will be entered for the respondent.

Petitioner constructed and placed in service a freezer facility and claimed an investment credit with respect thereto under sec. 38, I.R.C. 1954. Held, petitioner is not entitled to an investment credit with respect to the freezer facility under sec. 38, I.R.C. 1954, because the freezer facility…

2Cases cited6 opinions

  1. United States v. DrumSupreme Court of the United States · 1962
  2. Commissioner of Internal Revenue v. Schuyler Grain Co., Inc.Court of Appeals for the Seventh Circuit · 1969
  3. Schuyler Grain Co. v. CommissionerUnited States Tax Court · 1968
  4. Mt. Mansfield Co. v. CommissionerUnited States Tax Court · 1968
  5. Vail Assocs. v. CommissionerUnited States Tax Court · 1987

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