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''Midland Empire Packing Company v. 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. The costs were held to be repairs, and thus deductible as an ordinary and necessary business expense under section 162(a) of the Internal Revenue Code. ==Facts== The petitioner, Midland Empire Packing Company (Midland), was the owner of a meat-packing plant in the State of Montana. The basement rooms of Midland's plant were used for the curing of hams and bacon and for the storage of meat and hides. The original concrete walls and floors were not sealed against water. When the water in the nearby Yellowstone River was high, the underground water caused increase seepage in the plant. Also near the plant was an oil refinery owned by The Yale Oil Corporation. In 1943 Midland discovered that oil from the refinery was seeping into Midland's water wells and the basement. The oil emitted a strong odor and created a fire hazard. Federal meat inspectors advised Midland that their options were to oilproof the basement and discontinue the use of the water wells, or shut down the plant. Midland had the basement walls sealed by independent contractors in the fiscal year ended November 30, 1943, at a cost of $4,868.81. The petitioner paid for the work during that year. On its tax returns for 1943, Midland deducted the $4,868.81 amount it paid for repairs on the theory, inter alia, it was an ordinary and necessary business expense under section 23(a) (162(a) ) of the Internal Revenue Code. The Internal Revenue Commissioner concluded that the cost of oilproofing was a non-deductible capital improvement to the business and should be recovered through depreciation charges. The petitioner challenged the Commissioner's finding in The United States Tax Court. 抄文引用元・出典: フリー百科事典『 ウィキペディア（Wikipedia）』 ■ウィキペディアで「Midland Empire Packing Co. v. Commissioner」の詳細全文を読む スポンサード リンク
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