Nulex, Inc. v. Commissioner
United States Tax Court
Petitioner, dormant at the time, purchased a boat in 1946 for the purpose of entering into the commercial chartering business. It could not secure a license for the boat and decided to sell it. Although petitioner originally entered the boat on its books as a fixed asset it carried it as an inventory item after the decision to sell Petitioner never used the boat and never claimed depreciation on it.
Read the full summary
Petitioner, dormant at the time, purchased a boat in 1946 for the purpose of entering into the commercial chartering business. It could not secure a license for the boat and decided to sell it. Although petitioner originally entered the boat on its books as a fixed asset it carried it as an inventory item after the decision to sell Petitioner never used the boat and never claimed depreciation on it. In 1952, it sold the boat for less than the purchase price and claimed the difference as a loss on cost of goods sold. Respondent disallowed the loss, reduced the basis by depreciation "allowable"…
1Opinion of the Court
The Commissioner determined a deficiency in petitioner’s income tax in the amount of $601.89 for the calendar year 1952. The deficiency for 1952 is due to the Commissioner’s disallowance of a loss claimed on the sale of a boat which petitioner purchased in 1946 but which was never used because of the inability to secure a charter license. The petitioner claims a deduction for the difference between the purchase price of the boat in 1946 and the selling price in 1952. The respondent reduced the basis of the boat by depreciation allegedly allowable for the period petitioner held it (even though…
2Cases cited2 opinions
- Sitterding v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1936
- United States v. EideCourt of Appeals for the Ninth Circuit · 1937
3Cited by14 opinions
- Richmond Television Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 1965
- Sears Oil Co., Inc., on Review v. Commissioner of Internal Revenue, on ReviewCourt of Appeals for the Second Circuit · 1966
- Cooper v. CommissionerUnited States Tax Court · 1959
- Lyle S. Simonson and Donna Simonson v. United StatesCourt of Appeals for the Eighth Circuit · 1985
- Hillcone S.S. Co. v. CommissionerUnited States Tax Court · 1963
9 more not listed; retrieve them via the Exa API.