# American Peanut Corp. v. Commissioner > United States Board of Tax Appeals · April 29, 1927 · 6 B.T.A. 1087 URL: https://www.frixlaw.com/law-library/cases/4499607 ## Case - **Full name:** AMERICAN PEANUT CORPORATION, v. COMMISSIONER OF INTERNAL REVENUE - **Court:** United States Board of Tax Appeals - **Decided:** April 29, 1927 - **Citations:** 6 B.T.A. 1087; 1927 BTA LEXIS 3323 - **Precedential status:** Published - **Opinion:** Opinion of the court by Trammbll - **Judges:** Trammbll - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/4499607 ## Opinion text *1089 OPINION. TRAmmbll : The only issue presented in this proceeding is whether the petitioner is entitled to a deduction on account of the replacements and repairs. On this issue we must approve the determination of the respondent. Eeplacements of the character here involved are capital expenditures. While repairs are deductible as expense, the respondent allowed such amounts as were shown to be for repairs in determining the‘proposed deficiency and disallowed only such portion of the amounts expended as he considered to be capital expenditures or for replacements. No portion of the amount disallowed is shown to have been expended for repairs. The machinery and equipment installed after the accident were of a different kind from that destroyed and damaged and a considerable portion of that removed was not destroyed or physically affected by the accident. Judgment will be entered on 15 days' notice, under Rule 50. --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/4499607. Public record. Not legal advice.