Kent v. Commissioner
United States Tax Court
1. Held, petitioner was engaged in the "trade or business" of farming for profit during the taxable year 1947. Sections 23 (a) (1) (A) and 23 (1) (1) of the Internal Revenue Code. 2. Held, expenditures for gatekeeper's salary and electricity, gas and fuel oil (some of which was used to heat vacant farm superintendent's house in order to prevent freezing of water pipes) were "ordinary and necessary" business expenses under Sec. 23 (a) (1) (A), I.R.C. 3. Held: (a) depreciation…
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1. Held, petitioner was engaged in the "trade or business" of farming for profit during the taxable year 1947. Sections 23 (a) (1) (A) and 23 (1) (1) of the Internal Revenue Code. 2. Held, expenditures for gatekeeper's salary and electricity, gas and fuel oil (some of which was used to heat vacant farm superintendent's house in order to prevent freezing of water pipes) were "ordinary and necessary" business expenses under Sec. 23 (a) (1) (A), I.R.C. 3. Held: (a) depreciation deduction on tenant house disallowed because useful economic life of that farm structure had terminated prior to 1947;…
1Opinion of the Court
Otis Beall Kent v. Commissioner.
Kent v. Commissioner
Docket No. 37332.
United States Tax Court
1953 Tax Ct. Memo LEXIS 10; 12 T.C.M. (CCH) 1491; T.C.M. (RIA) 54011;
December 31, 1953
1. Held, petitioner was engaged in the "trade or business" of farming for profit during the taxable year 1947. Sections 23 (a) (1) (A) and 23 (1) (1) of the Internal Revenue Code.
2. Held, expenditures for gatekeeper's salary and electricity, gas and fuel oil (some of which was used to heat vacant farm superintendent's house in order to prevent freezing of water pipes) were "ordinary and necessary" business expenses…
2Cases cited21 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Higgins v. CommissionerSupreme Court of the United States · 1941
- Kornhauser v. United StatesSupreme Court of the United States · 1928
16 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Steen v. CommissionerUnited States Tax Court · 1973
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- Steen v. CommissionerUnited States Tax Court · 1973