Hillyer, Deutsch, Edwards, Inc. v. Commissioner
United States Board of Tax Appeals
1. Salvage value of logging equipment determined from the evidence. 2. In determining the unit rate of depreciation per thousand feet as a step in computing depreciation upon the unit-of-production basis, both the additions to the physical equipment account and the additions to the available timber account should, in the absence of evidence showing the exact date such additions were made, be averaged over the entire year. 3. A certain contract held to be an assignment of a…
Read the full summary
1. Salvage value of logging equipment determined from the evidence. 2. In determining the unit rate of depreciation per thousand feet as a step in computing depreciation upon the unit-of-production basis, both the additions to the physical equipment account and the additions to the available timber account should, in the absence of evidence showing the exact date such additions were made, be averaged over the entire year. 3. A certain contract held to be an assignment of a prior contract rather than a novation thereof. 4. Evidence held insufficient to overcome the prima facie correctness of…
1Opinion of the Court
*459OPINION.
Love :
The issues here involve the amount, if any, of depreciation and’ depletion, or rather the exhaustion of the value of the Southwestern Co. contract, which petitioner is entitled to deduct from its gross income for the calendar years 1923 to 1926, inclusive. The amounts deducted by petitioner in its income-tax returns and the amounts allowed by the respondent in his deficiency letters have been set out in our findings. The amounts now claimed by petitioner, as alleged in its petitions, are as follows:
[[Image here]]
On the other hand, the respondent, at the close of the hearing,…
2Cited by3 opinions
- Ocrant v. CommissionerUnited States Tax Court · 1976
- Hillyer, Deutsch, Edwards, Inc. v. CommissionerUnited States Board of Tax Appeals · 1930
- Ocrant v. CommissionerUnited States Tax Court · 1976