Court Case Index

How to use this library of cases

Start with the legal question, not the caption. Personal-property versus structural-component questions under MACRS go to Hospital Corporation of America and Action on Decision 1999-008. Permanence questions go to Whiteco. Electrical splits go to Scott Paper and the electrical-allocation topic page. Written purchase-price allocations go to the Peco Foods discussion on the topic and tax-law pages. That order keeps a memorandum apartment case from being treated as if it rewrote the Code.

Weight the court before you weight the result. A Supreme Court opinion binds nationally. A court of appeals opinion binds in that circuit. A regular Tax Court opinion is precedential in the Tax Court. A memorandum opinion is fact-specific. A permanence factor from a sign case does not automatically decide an office partition.

Named decisions with their own pages

Hospital Corporation of America & Subsidiaries v. Commissioner, 109 T.C. 21 (1997), is the leading MACRS classification opinion in this library. The Tax Court held that the investment-tax-credit tests in Treas. Reg. §1.48-1 still decide whether an item is tangible personal property or a structural component after ACRS and MACRS. The statutory bar on component depreciation of buildings does not erase that classification. IRS Action on Decision 1999-008 acquiesced in that legal test and nonacquiesced in the item-by-item results. The named page is written from the AOD and the opinion header that were opened.

Whiteco Industries, Inc. v. Commissioner, 65 T.C. 664 (1975), supplies the six permanence factors examiners still quote — movability, design to remain, intended duration, difficulty of removal, damage on removal, and manner of affixation. The court treated outdoor advertising signs as tangible personal property. The IRS later treated those criteria as the working inherently-permanent inquiry.

Scott Paper Co. v. Commissioner, 74 T.C. 137 (1980), is the functional-allocation case. Primary electric is a structural component only to the extent it powers building operation and maintenance; the process share can be personal property. Publication 5653 discusses the later IRS statement that the Service would not challenge a properly applied allocation of primary and secondary electrical distribution.

Idaho Power, Lincoln Savings, and INDOPCO sit on the repairs-and-capitalization pages. Massey Motors and Alamo Broadcasting are pre-MACRS useful-life opinions kept as history. Walling and Plainfield-Union are repair-versus-capital cases. Simon is an ACRS useful-life case, not a building-classification template. Metro National is cited from the IRS written determination and the Audit Techniques Guide table that were opened.

Topic pages and decisions without their own URL

Topic pages group holdings by issue. Structural-component pages collect Treas. Reg. §1.48-1(e)(2), Whiteco, and Hospital Corporation of America. Electrical pages collect Scott Paper, Morrison, and Publication 5653 Chapter 8. Land-improvement pages collect class 00.3 material and cases such as Trentadue. Repair pages collect Plainfield-Union, Walling, Lincoln Savings, and INDOPCO. Evidence pages collect inspection, cost support, and legal explanation — not a product-name stamp.

AmeriSouth XXXII, Ltd. v. Commissioner, T.C. Memo. 2012-67, and Peco Foods, Inc. v. Commissioner, T.C. Memo. 2012-18, affirmed in an unpublished Eleventh Circuit opinion (No. 12-12169, July 2, 2013), are the modern caution cases. AmeriSouth is the aggressive apartment-list case: most contested items were held §1250; a few categories were held §1245. Peco Foods is the written-allocation case: residual-method schedules in two poultry-plant purchases bound the buyer, and a later cost-segregation study could not subdivide “Processing Plant Building” into shorter-life components. Those decisions are discussed on topic and tax-law pages because the inventory did not give them named URLs.

Morrison, King Radio, A.C. Monk, Boddie-Noell, Shoney’s South, and Trentadue appear on topic pages with the sources that were opened. Where the opinion itself was not opened and the citation comes from Publication 5653’s case table, the topic page says so. This index does not upgrade those rows into full holdings.

Captions that are not classification cases

L.A. Darling Co. v. Commissioner, Sperry and Hutchinson Co. v. Commissioner, Clemens v. Commissioner, and Yellow Cab Co. v. Commissioner now have bodies. The bodies state the decision that was opened. They do not invent a cost-segregation holding to match the inventory title.

No federal tax opinion was located under L.A. Darling Company. The nearest Darling depreciation decision is Jay N. Darling, 4 B.T.A. 499 (1926). The Sperry & Hutchinson tax decision that was opened is an Oregon interest-apportionment case. Clemens v. Commissioner, T.C. Memo. 1989-205, is a sick-leave exclusion. Yellow Cab Co. v. Commissioner, 35 T.C. 791 (1961), is excess-profits-tax relief. Idle-cab depreciation is Yellow Cab Co. of Pittsburgh v. Driscoll, 24 F. Supp. 993 (1938), a different caption. Do not cite any of the four for a building class.

What this index does not do

It does not rank studies, promise audit outcomes, or turn a memorandum item list into a nationwide classification table. It does not treat Publication 5653’s case tables as a substitute for the opinions. The Audit Techniques Guide is examiner guidance; the guide itself says it is not an official pronouncement of law and cannot be cited as authority.

It does not claim that Super Intelligence agents have read or ranked these cases. Any workflow labels on this site that use that vocabulary are proposed or explanatory. A reader who needs advice about a specific building should take the named opinion and the facts to a CPA or tax attorney. This index is a map of what CostSeg SI opened, not a court.