Legal Opinion

Kent v. Commissioner

United States Tax Court

Decided December 31, 1953No. Docket No. 37332UnpublishedCited by 3 opinions

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

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Commissioner v. HeiningerSupreme Court of the United States · 1943
  4. Higgins v. CommissionerSupreme Court of the United States · 1941
  5. Kornhauser v. United StatesSupreme Court of the United States · 1928

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

3Cited by3 opinions

  1. Steen v. CommissionerUnited States Tax Court · 1973
  2. Maier Brewing Co. v. CommissionerUnited States Tax Court · 1987
  3. Steen v. CommissionerUnited States Tax Court · 1973

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