TAX 9863 Lecture Notes - Lecture 23: Amt (Country Subdivision)
Document Summary
Philadelphia park amusement co. v. u. s. , casebook, p. 116: prof. handler. In the court of claims which is roughly equivalent to district court in the sense that decision goes to court of appeals for review. How old is case= 65 y/o and a lower court decision. Tp deeded bridge to city in exchange for 10 yr ext. of franchise to operate a passenger railway. Tp abandoned his franchise 10 years later [presumably because he was not making any $ on it] Basis for franchise which included 10 yr ext. became important when tp claimed depreciation deductions on the franchise and also claimed a loss of abandonment for franchise. Can take a loss deduction if you own business investment asset that becomes worthless. Also take loss deduction if show you abandoned the asset. There is overlap of worthlessness and abandonment. Defendant [government] contends that the strawberry bridge which was exchanged was worthless when exchanged thus there was zero basis.
