Gibson & Associates, Inc. v. Commissioner
United States Tax Court
P is an engineering and heavy construction company that primarily erects or rehabilitates streets, bridges, airport runways, and other related real property (collectively, real property). P's rehabilitation services relate mainly to real property that is substantially dilapidated or damaged from a casualty. P also repairs and maintains real property.
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P is an engineering and heavy construction company that primarily erects or rehabilitates streets, bridges, airport runways, and other related real property (collectively, real property). P's rehabilitation services relate mainly to real property that is substantially dilapidated or damaged from a casualty. P also repairs and maintains real property. P reported on its Federal income tax return for the taxable year ended June 30, 2006, that its receipts are "domestic production gross receipts" (DPGR) eligible for a deduction under sec. 199, I.R.C., and claimed a $63,435 deduction under that…
1Opinion of the Court
Paris, Judge:
Petitioner petitioned the Court to redetermine respondent’s determination of a $21,568 deficiency in its Federal income tax for its taxable year ended June 30, 2006 (subject year). The deficiency results from respondent’s determination that petitioner may not deduct $63,435 under section 199(a). Respondent disallowed that deduction after determining that petitioner had no “domestic production gross receipts” (dpgr) within the meaning of section 199(c)(4). Petitioner reported that its DPGR totaled $26,053,570.
Respondent now concedes that petitioner had DPGR of $13,849,246, and…
2Cases cited22 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
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- Helvering v. BlissSupreme Court of the United States · 1934
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