Opinion

The Connecticut Light and Power Company v. The United States

  • 299 F.2d 259
  • 156 Ct. Cl. 304
  • 9 A.F.T.R.2d (RIA) 675
  • 1962 U.S. Ct. Cl. LEXIS 36
Court
United States Court of Claims
Filed
Feb 7, 1962
Status
Published
Author
Whitaker
On the bench
Jones, Whitaker, Reed, Durfee, Lara-More
Cited by
9 cases
Authority
More cited than 24.7%

natural gas company entitled to deduct currently costs of converting customer appliances

How later courts described this case

  • natural gas company entitled to deduct currently costs of converting customer appliances

Written by the judges who cited it.

The opinion

WHITAKER, Judge

(dissenting).

There is much to be said for the opinion of the majority, but I am inclined to think that the expenditures for the adaptation of customers’ appliances to the use of natural gas are not deductible as ordinary and necessary business expenses for this reason:

The expenditures plaintiff made to convert the equipment in its own plants and pipe lines for the use of natural gas were not ordinary and necessary business expenses, but undoubtedly were capital expenditures. But these capital expenditures were worthless without the conversion also of its customers’ appliances. In order to give value to its own equipment, it was required to spend money to convert its customers’ appliances. The money so spent should be added to the cost of conversion of its own equipment and deducted, by way of depreciation or amortization, over a period of years, and not wholly in the year expended. Cf. Teitelbaum v. Commissioner, 7 Cir., 294 F.2d 541 .

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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