Legal Opinion

Starr v. Commissioner

United States Tax Court

Decided June 30, 1958No. Docket No. 59307PublishedCited by 17 opinions

Held, certain payments made under a "Lease Form of Contract" for a sprinkler system are not deductible as rental expenses under section 23 (a) (1) (A), I. R. C. 1939, but were capital expenditures.

1Opinion of the Court

Bruce, Judge:

Respondent determined deficiencies in income tax and additions to tax of Delano T. Starr and Mary W. Starr as follows:

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Delano T. Starr died after tbe petition was filed and bis widow, Mary W. Starr, executrix of tbe last will and testament of Delano T. Starr, was substituted in bis stead.

Tbe sole issue for decision is whether payments made for the installation of a building sprinkler system in tbe amount of $1,240 for each of tbe years 1951 and 1952 are deductible as rental expenses within tbe meaning of section 23 (a) (1) (A), I. K,. C. 1939, or whether these…

2Cases cited9 opinions

  1. Walburga Oesterreich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
  2. Haggard v. CommissionerUnited States Tax Court · 1955
  3. D. M. Haggard and Nila Haggard v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
  4. Mills v. CommissionerUnited States Tax Court · 1948
  5. Benton v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1952

4 more not listed; retrieve them via the Exa API.

3Cited by17 opinions

  1. Estate of Delano T. Starr, Deceased, Mary W. Starr, and Mary W. Starr v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
  2. Kansas City S. R. Co. v. CommissionerUnited States Tax Court · 1981
  3. Western Contracting Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1959
  4. Swift Dodge v. CommissionerUnited States Tax Court · 1981
  5. Irby v. CommissionerUnited States Tax Court · 1958

12 more not listed; retrieve them via the Exa API.

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