Legal Opinion

L&B Corp. v. Commissioner

United States Tax Court

Decided April 6, 1987No. Docket Nos. 32911-84, 32935-84, 33261-84PublishedCited by 7 opinions

Petitioners' partnerships placed in service refrigerated structures, truck turn-arounds, and railroad trackage during the years in issue. Meat packers and other independent parties rented or leased space in the refrigerated structures primarily for the cold storage of various meats and certain other food products. Petitioners sought investment tax credits under sec. 38, I.R.C. of 1954, as amended, with respect to costs relating to the structures.

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Petitioners' partnerships placed in service refrigerated structures, truck turn-arounds, and railroad trackage during the years in issue. Meat packers and other independent parties rented or leased space in the refrigerated structures primarily for the cold storage of various meats and certain other food products. Petitioners sought investment tax credits under sec. 38, I.R.C. of 1954, as amended, with respect to costs relating to the structures. Respondent allowed credits only with respect to certain refrigeration system components of the refrigerated structures. Held, the refrigerated…

1Opinion of the Court

COHEN, Judge:

Respondent determined the following deficiencies in petitioners’ Federal income taxes and claimed, by amendments to answer, the following increased deficiencies in petitioners’ Federal income taxes:

Petitioner Year Increased Deficiency deficiency

L&B Corp. 2/28/75 2/29/76 2/28/79 2/29/80 2/28/81 $10,353.89 307.58 18,991.04 19,590.06 17,249.75 $3,325.91

1976 1977 1978 1979 1980 Larry A. Larsen and Betty J. Larsen 9,301.73 22,770.73 13,916.15 27,177.68 20,708.32 4,096.49

1976 1977 1978 1979 1980 Estate of Howard C. Larsen, deceased, and Maxine J. Larsen 6,803.23 1,903.85 11,843.21…

2Cases cited21 opinions

  1. Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
  2. Casey v. CommissionerUnited States Tax Court · 1962
  3. Catron v. CommissionerUnited States Tax Court · 1968
  4. Central Citrus Co. v. CommissionerUnited States Tax Court · 1972
  5. Consolidated Freightways, Inc. & Affiliates v. CommissionerUnited States Tax Court · 1980

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

3Cited by7 opinions

  1. Loda Poultry Co. v. CommissionerUnited States Tax Court · 1987
  2. Texas Instruments v. CommissionerUnited States Tax Court · 1992
  3. L & B Corp. v. CommissionerCourt of Appeals for the Eighth Circuit · 1988
  4. L & B Corporation, a Nebraska Corporation v. Commissioner of Internal Revenue, Larry A. Larsen and Betty J. Larsen v. Commissioner of Internal Revenue, Estate of Howard C. Larsen, Deceased, Maxine J. Larsen, and Maxine J. Larsen v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1988
  5. Des Moines Cold Storage Co. v. CommissionerUnited States Tax Court · 1988

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

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