Legal Opinion

Thompson v. Commissioner

United States Tax Court

Decided December 15, 1967No. Docket No. 879-66PublishedCited by 5 opinions

Investment Credit. -- On Dec. 4, 1957, petitioners entered into a lease agreement with the owners of certain premises located in Tucson, Ariz., for a period of over 8 years. Shortly thereafter petitioners conducted on these leased premises a business known as Redwood Lodge until Apr. 2, 1962. On that date petitioners sold the business, including all the personal property used in connection therewith, to Redwood Gay Nineties Lodge, a corporation.

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Investment Credit. -- On Dec. 4, 1957, petitioners entered into a lease agreement with the owners of certain premises located in Tucson, Ariz., for a period of over 8 years. Shortly thereafter petitioners conducted on these leased premises a business known as Redwood Lodge until Apr. 2, 1962. On that date petitioners sold the business, including all the personal property used in connection therewith, to Redwood Gay Nineties Lodge, a corporation. To secure part of the purchase price, a note and chattel mortgage were given. The purchasers failed to make the payments on the said note and…

1Opinion of the Court

OPINION

Among the errors assigned by petitioners is the following:(b) The Commissioner erroneously determined, that none of the assets acquired in 1963 in connection with repossession of the Redwood Lodge qualified for an investment credit under section 38, et seq., of the Internal Revenue Code;

Section 38,1.R.C. 1954, is in the margin.1 Subpart B of chapter 1, subch. A, part IV, I.R.C. 1954, comprises three sections, namely, 46, 47, and 48, the applicable provisions of which are in the margin.2 Under tbe applicable provisions quoted in footnote 2, petitioners would compute the credit here…

2Cases cited1 opinion

  1. Madison Newspapers, Inc. v. CommissionerUnited States Tax Court · 1967

3Cited by5 opinions

  1. Crawford v. CommissionerUnited States Tax Court · 1978
  2. Crawford v. CommissionerUnited States Tax Court · 1978
  3. Kleuskens v. CommissionerUnited States Tax Court · 1982
  4. Thompson v. CommissionerUnited States Tax Court · 1967
  5. Travis v. CommissionerUnited States Tax Court · 1980

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