| 翻訳と辞書 |
| Philadelphia Park Amusement Co. v. United States ： ウィキペディア英語版 |
Philadelphia Park Amusement Co. v. United States
In Philadelphia Park Amusement Co. v. United States, 126 F.Supp. 184, the United States Court of Claims ruled that the cost basis of property received in a taxable exchange is the fair market value of the property received.
== Background ==
Strawberry Bridge was owned by the taxpayer and, after it was discovered that the bridge needed significant repairs, the taxpayer gave the bridge to the City of Philadelphia in exchange for a 10-year extension of the taxpayer's railway franchise in Fairmount Park which was owned by the City of Philadelphia. Since the 10-year extension had no market value, the taxpayer used the depreciating bridge as his new basis, then proceeded to claim overpayment of tax due to his failure to claim any depreciation. The Internal Revenue Service disagreed with the taxpayer’s reasoning, and disallowed his claim for a larger depreciation deduction.〔Philadelphia Park Amusement Co. v. United States, 126 F. Supp. 184 (US Ct. of Claims, 1954).〕
Initially, a disagreement also arose out of the fact that the Commissioner amortized the original cost of the franchise over the period beginning on the date the franchise was granted, while the taxpayer amortized it over the period beginning on the date the railway began operating.〔 However, this disagreement was abandoned by the both parties and is not mentioned in either parties’ brief, nor was there any mention of it during the oral arguments.〔(''Philadelphia Park'', 126 F. Supp. at 187 )〕
The opinion was written by Judge Laramore, with Judges Madden, Whitaker, Littleton, and Chief Judge Jones all concurring. No concurring opinion was published.〔
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「Philadelphia Park Amusement Co. v. United States」の詳細全文を読む
スポンサード リンク
| 翻訳と辞書 : 翻訳のためのインターネットリソース |
Copyright(C) kotoba.ne.jp 1997-2016. All Rights Reserved.
|
|