- 2 - After concessions, the issue for decision is whether petitioner may deduct or must capitalize the expenses of relocating a portion of its pipeline.1 Background This case was submitted fully stipulated under Rule 122.2 The stipulation of facts, supplemental stipulation of facts, and attached exhibits are incorporated herein by this reference. Petitioner is a corporation, whose principal office was located in Tulsa, Oklahoma, at the time the petition was filed. It timely filed its 1991 tax return with the Internal Revenue Service Center, Austin, Texas. Petitioner operates a common carrier refined products pipeline system transporting refined petroleum products in the States of Illinois, Indiana, and Wisconsin. The system consists of approximately 335 miles of pipeline. Approximately 25 miles of the pipeline consists of 16-inch pipe; the remainder consists of 12-inch or smaller pipe. Petitioner's pipeline system is located on both private and public property. Because it is not always possible or 1 If we decide petitioner must capitalize all or some of these expenses, then petitioner will be entitled to a corresponding depreciation allowance. 2 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the taxable year at issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011