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The taxpayer argued that these expenses were deductible, but the IRS stated that the costs should be capitalized. The court held that the inspection and replacement costs could be deducted because the improvements did not add to the value and did not prolong the life of the airplanes as a whole. [11]
Welch v. Helvering, 290 U.S. 111 (1933), was a decision by the United States Supreme Court on the difference between business and personal expenses and the difference between ordinary business deductions and capital expenses. It is one of the most important income tax law cases.
The Second Circuit Court of Appeals reversed the Tax Court and held it to be a capital loss. [2] The U.S. Supreme Court agreed with the Second Circuit and held that it was a capital loss. [1] Allowing the income from the liquidation to be taxed as a capital gain, while allowing loss payments out of that income to be deducted as an ordinary ...
Commissioner, 14 T.C. 635 (1950), was a case in which the United States Tax Court ruled that Midland Empire Packing Company was permitted to deduct the costs of lining its basement walls and floor. [1] The costs were held to be repairs, and thus deductible as an ordinary and necessary business expense under section 162(a) of the Internal ...
Because business expenses are fully deductible under section 162, taxpayers try to argue that expenses were not start up expenses. The Second Circuit Court of Appeals found that the Tax Court should look at if employment of the taxpayer is in the same trade or business to determine if it is a start-up expense, or a carrying on expense. [11]
Thor Power Tool Company v. Commissioner, 439 U.S. 522 (1979), was a United States Supreme Court case in which the Court upheld IRS regulations limiting how taxpayers could write down inventory. Thor manufactured equipment using multiple parts that it produced. It capitalized the costs of these parts when produced.
Though these payments qualified for § 162 deduction as expenses paid in the course of the opticians' trade or business, the IRS argued that the expenses should be disallowed as against public policy. [8] While the Court disapproved of the business ethics displayed by the opticians, the Court upheld the deductions as valid under the Code. [8]
Commissioner v. Flowers, 326 U.S. 465 (1946), was a Federal income tax case before the Supreme Court of the United States. [1] The Court held that in order to deduct the expense of traveling under § 162 of the Internal Revenue Code, the expense must be incurred while away from home, and must be a reasonable expense necessary or appropriate to the development and pursuit of a trade or business.