Moore v. Commissioner
United States Tax Court
The petitioner-husband purchased trailers during 1965 and 1966 which he located on his trailer park. He rented these trailers to tenants who stayed at the trailer park for varying periods of time. Held: 1. The petitioners are not entitled to the credit against tax (investment credit) allowed by sec. 38 of the 1954 Code.
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The petitioner-husband purchased trailers during 1965 and 1966 which he located on his trailer park. He rented these trailers to tenants who stayed at the trailer park for varying periods of time. Held: 1. The petitioners are not entitled to the credit against tax (investment credit) allowed by sec. 38 of the 1954 Code. The trailers do satisfy the requirement in sec. 48(a)(1) that "section 38 property" be tangible personal property; they are not "buildings or other inherently permanent structures" on land under sec. 1.48-1(c), Income Tax Regs. However, because the trailers were "used…
1Opinion of the Court
Hoyt, Judge:
The respondent determined deficiencies in the petitioners’ income tax and additions to the tax under section 6653(a) of the 1954 Code for the calendar years and in the amounts listed below:
Year Deficiency Additions to tax sec. 6668(a)
1965__ $3,689.19 $184.46
1966_ 3,805.89 190. 29
The issues presented for our decision are (1) whether mobile homes purchased in the years 1965 and 1966 qualify as “section 38 property,” thereby entitling the petitioners to the credit against the tax allowed by section 38 1 of the 1954 Code, and (2) whether the said mobile homes qualify as “section 179…
2Cases cited2 opinions
- Catron v. CommissionerUnited States Tax Court · 1968
- Central Citrus Co. v. CommissionerUnited States Tax Court · 1972
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- Scott Paper Co. v. CommissionerUnited States Tax Court · 1980
- Illinois Cereal Mills, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- La Croix v. CommissionerUnited States Tax Court · 1974
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