Legal Opinion

CSX Corp. v. Commissioner

United States Tax Court

Decided July 23, 1987No. Docket Nos. 7521-82, 30341-83PublishedCited by 11 opinions

P is the common parent corporation of an affiliated group of corporations involved in various railroad related activities.

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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

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. United States v. CorrellSupreme Court of the United States · 1967
  3. Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
  4. Burnet v. HoustonSupreme Court of the United States · 1931
  5. Russell v. PlaceSupreme Court of the United States · 1877

22 more not listed; retrieve them via the Exa API.

3Cited by11 opinions

  1. Charles L. Knapp and Beverley E. Knapp v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1989
  2. Robinson v. Comm'rUnited States Tax Court · 2002
  3. Newborn v. CommissionerUnited States Tax Court · 1990
  4. Miller v. CommissionerUnited States Tax Court · 1989
  5. Estate of Allen v. CommissionerUnited States Tax Court · 1989

6 more not listed; retrieve them via the Exa API.

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