Southern Pacific Transp. Co. v. Comm'r of Internal Revenue
| Decision Date | 31 December 1980 |
| Docket Number | Docket No. 3493-69. |
| Citation | Southern Pacific Transp. Co. v. Comm'r of Internal Revenue, 75 T.C. 497 (T.C. 1980) |
| Parties | SOUTHERN PACIFIC TRANSPORTATION COMPANY, PETITIONER V COMMISSIONER of INTERNAL REVENUE, RESPONDENT v. COMMISSIONER of INTERNAL REVENUE, RESPONDENT |
| Court | U.S. Tax Court |
Get this document and AI-powered insights with a free trial of vLex and Vincent AI
Get Started for FreeStart Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your Free Trial of vLex and Vincent AI, Your Precision-Engineered Legal Assistant
-
Access comprehensive legal content with no limitations across vLex's unparalleled global legal database
-
Build stronger arguments with verified citations and CERT citator that tracks case history and precedential strength
-
Transform your legal research from hours to minutes with Vincent AI's intelligent search and analysis capabilities
-
Elevate your practice by focusing your expertise where it matters most while Vincent handles the heavy lifting
Start Your Free Trial
123 cases
-
Waddell v. Comm'r of Internal Revenue
... ... Woodward v. Commissioner, supra, 397 U.S, at 575-576; Southern Pacific Transportation Co. v. Commissioner, 75 T.C. 497, 577-578 (1980) ... ...
-
Guardian Indus. Corp. & Subsidiaries v. Comm'r of Internal Revenue, Docket No. 27308-87.
... ... 1969), affg. per curiam a Memorandum Opinion of this Court; Southern Pacific Transportation Co. v. Commissioner, 75 T.C. 497, 663-664, 703-704 ... ...
-
Kansas City Southern Ry. Co. v. Comm'r of Internal Revenue
... ... See Lykes Bros. Steamship Co. v. United States , 206 Ct. Cl. 354, 513 F.2d 1342 (1975); Pacific Far East Line, Inc. v. United States , 206 Ct. Cl. 378, 513 F.2d 1355 (1975). See also sections ... ...
-
Mecom v. Comm'r of Internal Revenue
... ... Southern Pac. Transp. Co. v. Commissioner, 75 T.C. 497, 840 (1980). The ... ...
Get Started for Free
1 firm's commentaries
-
Tax Court In Brief | Ziroli v. Commissioner | Is A Disgorgement Payment A Deductible Business Expense Under Section 162?
...of the disgorgement in the instant case depends on "the purpose which the statutory penalty is to serve." Pac. Trans. Co. v. Commissioner, 75 T.C. 497, 653 (1980). Civil "imposed for purposes of enforcing the law and as punishment for the violation thereof" are "similar" penalties under sec......
3 books & journal articles
-
Tax Consequences and Planning Opportunities: Crime Doesn't Pay but It May Be Tax-Deductible
...v. Comm’r, 88 T.C. 1384, 1387 (1987), aff’d, 850 F.2d 611 (9th Cir. 1988); Huff v. Comm’r, 80 T.C. 804, 824 (1983); S. Pac. Transp. Co. v. Comm’r, 75 T.C. 497, 646–54 (1980); Allied-Signal, Inc. v. Comm’r, T.C. Memo 1992-204. Where a payment may include both components, punitive (nondeducti......
-
What isn't a change in method of accounting?
...in the way the taxpayer reported $88,000 of gain over three taxable years was material. In Southern Pacific Transp. Co. v. Commissioner, 75 T.C. 497, 684 (1980), the Tax Court declined to create an exception from the regulations' definition of "material item" for a change in the treatment o......
-
Adherence to utility regulations is an accounting method.
...of that allowed for tax purposes, intending to make adjustments later. Tax Court In FPL, the court followed Southern Pac. Transp. Co., 75 TC 497 (1980), a case similar to FPL, involving a taxpayer subject to the Interstate Commerce Commission's (ICC's) regulatory accounting rules on capital......