Randolph Bldg. Corp. v. Commissioner
United States Tax Court
Petitioner purchased improved real property in the "loop" area of Chicago. The highest and best use of the property required retention of the building located thereon. The building was renovated, and as improved had a useful life of 20 years, after which the parties project that the highest and best use of the property will require demolition of the building.
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Petitioner purchased improved real property in the "loop" area of Chicago. The highest and best use of the property required retention of the building located thereon. The building was renovated, and as improved had a useful life of 20 years, after which the parties project that the highest and best use of the property will require demolition of the building. For depreciation purposes the purchase price must be allocated between the land and the physical improvements in the same proportion that the value of the depreciable property bears to the value of the entire property. Petitioner, in…
1Opinion of the Court
Wilbur, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes as follows:
TYE Aug. 31— Deficiency TYEAug. 31— Deficiency
1968. $70,669.63 1970. $1,417.02
1969. 57,611.24 1971. 59,155.57
Due to concession by the parties, the sole issue remaining for decision is the proper amount of depreciation deductible by the petitioner in the years in issue with respect to property purchased by it in 1967. This requires us to apportion the purchase price paid by petitioner for real estate between the land and physical improvements thereon.
FINDINGS OF FACT
Some of the facts have been…
2Cases cited3 opinions
- Appleby v. CommissionerUnited States Board of Tax Appeals · 1940
- Commissioner of Internal Rev. v. Appleby's EstateCourt of Appeals for the Second Circuit · 1941
- Phipps Estates v. CommissionerUnited States Tax Court · 1945
3Cited by12 opinions
- Broz v. Comm'rUnited States Tax Court · 2011
- Avedisian v. CommissionerUnited States Tax Court · 1987
- Clayton v. CommissionerUnited States Tax Court · 1981
- Meiers v. CommissionerUnited States Tax Court · 1982
- Broz v. Comm'rUnited States Tax Court · 2011
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