Pelaez & Sons, Inc. v. Commissioner
United States Tax Court
Sec. 263A, I.R.C., enacted in 1986, requires the capitalization of developmental costs. For plants with preproduction periods that are 2 years or less, farmers may be excepted from the capitalization requirements. For certain plants, including citrus plants grown in commercial quantities in the United States, the statute requires that the standard for the 2-year test is to be based on a national weighted average preproductive period for that type of plant.
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Sec. 263A, I.R.C., enacted in 1986, requires the capitalization of developmental costs. For plants with preproduction periods that are 2 years or less, farmers may be excepted from the capitalization requirements. For certain plants, including citrus plants grown in commercial quantities in the United States, the statute requires that the standard for the 2-year test is to be based on a national weighted average preproductive period for that type of plant. If the preproductive period, so determined, is 2 years or less, citrus farmers could be excepted from the capitalization requirement of…
1Opinion of the Court
PELAEZ AND SONS, INC., CHRISTINA P. HOOKER, TAX MATTERS PERSON, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Pelaez & Sons, Inc. v. Commissioner
No. 18049-97
United States Tax Court
114 T.C. 473; 2000 U.S. Tax Ct. LEXIS 34; 114 T.C. No. 28;
May 30, 2000, Filed
Decision will be entered for respondent.
Sec. 263A, I.R.C., enacted in 1986, requires the
capitalization of developmental costs. For plants with
preproduction periods that are 2 years or less, farmers may be
excepted from the capitalization requirements. For certain
plants, including citrus plants grown in commercial quantities
in the…
2Cases cited14 opinions
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Burlington Northern Railroad v. Oklahoma Tax CommissionSupreme Court of the United States · 1987
- Sullivan v. StroopSupreme Court of the United States · 1990
- Graff Chevrolet Company v. Ellis Campbell, Jr., District Director of Internal RevenueCourt of Appeals for the Fifth Circuit · 1965
- First Chicago Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
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