TG Mo. Corp. v. Comm'r
United States Tax Court
P develops and uses production molds to manufacture automotive parts for its customers. P contracts with third-party toolmakers to build the production molds that P does not construct. After a third-party toolmaker finishes constructing a production mold, P purchases the mold and incurs additional design and engineering costs to modify the mold so that it can be used to produce the desired component part.
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P develops and uses production molds to manufacture automotive parts for its customers. P contracts with third-party toolmakers to build the production molds that P does not construct. After a third-party toolmaker finishes constructing a production mold, P purchases the mold and incurs additional design and engineering costs to modify the mold so that it can be used to produce the desired component part. P then either sells the completed production molds to its customers or retains ownership of the molds, but in either case P keeps the molds for production of automotive parts. On its 1998…
1Opinion of the Court
OPINION
Marvel, Judge:
Respondent determined deficiencies in petitioner’s Federal income tax of $3,815,746 and $1,544,033 for 1998 and 1999,1 respectively. After concessions,2 the sole issue for consideration is whether production molds petitioner sold to its customers are assets subject to depreciation for purposes of sections 41 and 174.3 The resolution of that issue determines whether the amounts petitioner paid to third-party toolmakers for the molds4 should have been included as “cost of supplies” in petitioner’s qualified research expenses for purposes of computing its tentative research…
2Cases cited27 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Robinson v. Shell Oil Co.Supreme Court of the United States · 1997
- Food & Drug Administration v. Brown & Williamson Tobacco Corp.Supreme Court of the United States · 2000
- United States v. JanisSupreme Court of the United States · 1976
- Gustafson v. Alloyd Co.Supreme Court of the United States · 1995
22 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Rand v. Comm'rUnited States Tax Court · 2013
- James Edward Bradley, Jr. & Margaret Letitia Hayes-Hunter v. CommissionerUnited States Tax Court · 2018
- Rand v. Comm'rUnited States Tax Court · 2013
- TG Missouri Corporation f.k.a. TG (U.S.A.) Corporation, a Missouri Corporation v. CommissionerUnited States Tax Court · 2009
- TG Mo. Corp. v. Comm'rUnited States Tax Court · 2009
4 more not listed; retrieve them via the Exa API.