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Income Tax Keyed to Bankman
Midland Empire Packing Co. v. Commissioner
Citation:
14 T.C. 635 (1950), acq., 1950-2 C.B. 3Facts
Petitioner operated a meat-packing plant for twenty-five years and had been using the plant’s basement rooms for curing and storing meat during that period. Over that duration, the basement had only experience intermittent water seepage which caused no meaningful disruption to operations. In the taxable year, oil from a nearby refinery was found to be seeping into the basement, creating a fire hazard and an objectional odor. Federal meat inspectors warned Petitioner that it must oil-proof its basement or the plant would be shut down. Petitioner complied by installing concrete lining in the basement, which it reported as an ordinary and necessary business expense on its tax return. The Commissioner of Internal Revenue asserted a deficiency, finding that the concrete lining was a capital investment and not an expense.
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