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23 T.C. 716

Knapp v. Commissioner

United States Tax Court

Decided January 26, 1955

United States Tax Court · decided 1955-01-26

Where freeze kills trees in citrus orchards used in trade or business and decreases value of land due to presence of dead trees, held: 1. Held: Land and trees are not to be considered as an integral unit in determining deductible loss under Internal Revenue Code (1939), section 23 (e). 2.

Good law ✅— No negative treatment on recordhow we know

Decisions will be entered under Rule 50 · Decided 1955-01-26

How this case has been cited

Cited by 18 later decisions — most recently July 1997

4 federal appellate ·

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Murdock, J.,

¶1dissenting: A loss deductible under section 23 (e) could result from a casualty to land, but this is not such a case. This land was not destroyed or damaged by the freeze but was just as good land thereafter as it was before. The damage was to the trees.

¶2A deduction might possibly be allowed on some other theory. For example, the cost of planting trees was allowed as an expense of this business, and perhaps the cost of removing them might also be an ordinary and necessary expense of the business, or, since the expense of removing the trees was so proximately related to the casualty (freezing of the trees) it might be deducted as a casualty loss over and above the loss of the trees, even though the freeze did no damage to the land itself.

Arundell, Van Fossan, and Harron, JJ., agree with this dissent.
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