Pacific Fruit Express Co. v. Commissioner
United States Tax Court
The petitioner, in computing its deduction for depreciation with respect to its railroad cars, adopted a class life in accordance with Rev. Proc. 62-21, 1962-2 C.B. 418, as amended, and met the reserve ratio test set forth therein without regard to the transition rules. During the years in issue, it made repairs on such cars.
Read the full summary
The petitioner, in computing its deduction for depreciation with respect to its railroad cars, adopted a class life in accordance with Rev. Proc. 62-21, 1962-2 C.B. 418, as amended, and met the reserve ratio test set forth therein without regard to the transition rules. During the years in issue, it made repairs on such cars. Held, any such repairs that appreciably extended the useful life of a railroad car were capital expenditures not deductible under sec. 162, I.R.C. 1954, and the determination of whether such repairs did appreciably extend the useful life of a railroad car is made on an…
1Opinion of the Court
OPINION
Simpson, Judge:
The respondent determined deficiencies of $539,-369.69 for 1964, $346,408.59 for 1965, and $308,353.34 for 1966 in the Federal income tax of the petitioner. The issues in this case have been severed, and the only issue to be decided herein is whether the petitioner, which adopted a class life for computing its depreciation deduction in accordance with Rev. Proc. 62-21, 1962-2 C.R. 418, as amended by Rev. Proc. 65-13, 1965-1 C.B. 759, and met the reserve ratio test set forth therein, without regard to the transition rules therein provided, can be denied a deduction under…
2Cases cited14 opinions
- Helvering v. Wilshire Oil Co.Supreme Court of the United States · 1939
- Helvering v. ReynoldsSupreme Court of the United States · 1941
- Illinois Merchants Trust Co. v. CommissionerUnited States Board of Tax Appeals · 1926
- Joseph Merrick Jones and Eugenie Penick Jones v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1957
- Oberman Mfg. Co. v. CommissionerUnited States Tax Court · 1967
9 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Wolfsen Land & Cattle Co. v. CommissionerUnited States Tax Court · 1979
- Matson Navigation Co. v. CommissionerUnited States Tax Court · 1977
- Keller Street Development Co. v. CommissionerUnited States Tax Court · 1978
- Matson Navigation Co. v. CommissionerUnited States Tax Court · 1977
- Pacific Fruit Express Co. v. CommissionerUnited States Tax Court · 1973
1 more not listed; retrieve them via the Exa API.