Appeals Stockbridge

Board of Tax Appeals

Appeals Stockbridge

2 B.T.A. 327

CourtUnited States Board of Tax Appeals

DecidedJuly 11, 1925

DocketDocket Nos. 1866, 1867, 1875, 1916, 1917

StatusPublished

This text of 2 B.T.A. 327 (Appeals Stockbridge) is published on Counsel Stack Legal Research, covering United States Board of Tax Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

Appeals Stockbridge, 2 B.T.A. 327 (bta 1925).

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Opinion

[328]*328OPINION.

Ivins:

We are satisfied by evidence submitted by the taxpayers-,, and uncontroverted, that depreciation should be allowed the partnership for the fiscal year ended June 30, 1919, in the amount of $29,698.73.

The item of $22,000 was not a proper deduction for the fiscal year in question. At the end of that year it represented not an accrued liability but a reserve.

During the fiscal year in question claims existed only in contemplation, not in fact. They did not arise and so accrue until after the-close of the fiscal year. Appeal of Consolidated Asphalt Co., 1 B. T. A. 79; Appeal of Henry Reubel, 1 B. T. A. 676; Appeal of Uvalde Co., 1 B. T. A. 932; Appeal of William J. Ostheimer, 1 B. T. A. 18.

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[328]*328OPINION.

Ivins:

We are satisfied by evidence submitted by the taxpayers-,, and uncontroverted, that depreciation should be allowed the partnership for the fiscal year ended June 30, 1919, in the amount of $29,698.73.

The item of $22,000 was not a proper deduction for the fiscal year in question. At the end of that year it represented not an accrued liability but a reserve.

During the fiscal year in question claims existed only in contemplation, not in fact. They did not arise and so accrue until after the-close of the fiscal year. Appeal of Consolidated Asphalt Co., 1 B. T. A. 79; Appeal of Henry Reubel, 1 B. T. A. 676; Appeal of Uvalde Co., 1 B. T. A. 932; Appeal of William J. Ostheimer, 1 B. T. A. 18.

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Bluebook (online)

2 B.T.A. 327, Counsel Stack Legal Research, https://law.counselstack.com/opinion/appeals-stockbridge-bta-1925.