Legal Opinion
Tunnell v. United States
District Court, D. Delaware
Decided November 28, 1973No. Civ. A. Nos. 4287, 4302PublishedCited by 1 opinion
1Opinion of the Court
OPINION
LATCHUM, Chief Judge.
This consolidated action arises out of a dispute between the plaintiffs1 and the Internal Revenue Service (“IRS”) over the depreciability of certain expenditures which the plaintiffs capitalized in the development of two mobile home park ventures owned and operated by them as partners in Sussex County, Delaware.
As a result of an IRS audit, the plaintiffs were notified in 1969 by the IRS that adjustments were being made to the plaintiffs’ partnership returns for 1966, 1967 and 1968 by disallowing certain deductions for depreciation and a deduction for an operating…
2Cases cited5 opinions
- Milton R. Psaty, and Martin M. Psaty v. United StatesCourt of Appeals for the Third Circuit · 1971
- D. Loveman & Son Export Corp. v. CommissionerUnited States Tax Court · 1960
- Southern Natural Gas Company v. The United StatesUnited States Court of Claims · 1969
- Norfolk Shipbuilding and Drydock Corp. v. United StatesDistrict Court, E.D. Virginia · 1971
- Clinton Cotton Mills v. Commissioner of Internal Rev.Court of Appeals for the Fourth Circuit · 1935
3Cited by1 opinion
- James M. Tunnell, Jr., and Mildred S. Tunnell v. The United States of America, Robert W. Tunnell and Eolyne K. Tunnell v. The United StatesCourt of Appeals for the Third Circuit · 1975