Schuyler Grain Co. v. Commissioner
United States Tax Court
Where petitioner's business included the harvesting, storage, aeration, drying, blending, manufacture, and shipment of grain, and where petitioner constructed five concrete grain storage bins to store grain in connection with its business operations, held, such storage facilities satisfied the requirements of sec. 48, I.R.C. 1954, and petitioner was therefore entitled to the investment tax credit provided for by sec. 38, I.R.C. 1954.
1Opinion of the Court
Withey, Judge:
The respondent determined a deficiency in petitioner’s income tax for its fiscal year ended August 31, 1964, in the amount of $2,319.10.
The sole issue presented is whether petitioner’s five grain storage bins constructed in the year in question were “used in connection with” any of the activities specified in section 48(a) (1) (B) (i) of the Internal Bevenue Code of 1954.1
FINDINGS OF FACT
Some of the facts have been stipulated and are found accordingly.
Schuyler Grain Company, Inc. (hereinafter referred to as petitioner), was incorporated on July 27, 1960, under the laws of the…
2Cited by27 opinions
- Catron v. CommissionerUnited States Tax Court · 1968
- Central Citrus Co. v. CommissionerUnited States Tax Court · 1972
- Northville Dock Corp. v. CommissionerUnited States Tax Court · 1969
- Munford, Inc. v. CommissionerUnited States Tax Court · 1986
- Moradian v. CommissionerUnited States Tax Court · 1969
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