CSX Corp. v. Commissioner
United States Tax Court
P is the common parent corporation of an affiliated group of corporations involved in various railroad related activities.
Read the full summary
P is the common parent corporation of an affiliated group of corporations involved in various railroad related activities. In the consolidated Federal corporation income tax returns filed for the 1972 and 1973 calendar years, certain member corporations of the affiliated group changed their method of depreciation from the 200-percent declining-balance method (DDB) to the straight-line method of depreciation, with respect to certain assets placed in service before Jan. 1, 1971. Beginning in 1973, certain member corporations of the affiliated group also began including in the depreciable basis…
1Opinion of the Court
TANNENWALD, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
Docket No.1 Year Deficiency
7521-82 1973 $2,373,810
30341-83 1974 100,000
1975 100,000
1976 2noo.ooo
After agreements by the parties, the remaining issues for decision are whether petitioner (1) in changing from the declining-balance method to the straight-line method of depreciation, must determine its depreciation allowance by utilizing a rate based on a whole-life or remaining-life calculation, and (2) is entitled to include in the depreciable basis of its roadway assets amounts for interest…
2Cases cited27 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- United States v. CorrellSupreme Court of the United States · 1967
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Burnet v. HoustonSupreme Court of the United States · 1931
- Russell v. PlaceSupreme Court of the United States · 1877
22 more not listed; retrieve them via the Exa API.
3Cited by11 opinions
- Charles L. Knapp and Beverley E. Knapp v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1989
- Robinson v. Comm'rUnited States Tax Court · 2002
- Newborn v. CommissionerUnited States Tax Court · 1990
- Miller v. CommissionerUnited States Tax Court · 1989
- Estate of Allen v. CommissionerUnited States Tax Court · 1989
6 more not listed; retrieve them via the Exa API.