Commissioner v. Idaho Power Co.
United States Supreme Court
418 U.S. 1 (1974)
The value of equipment owned by Idaho Power Company (IPC) (plaintiff) depreciated through the equipment’s use in daily operations and maintenance and in the construction of IPC’s capital improvements. Under § 167(a) of the federal tax code, the equipment’s operations- and maintenance-related depreciation entitled IPC to a business-expense tax deduction from IPC’s current gross income. IPC also claimed a § 167(a) deduction for its capital-construction-related equipment depreciation. The commissioner of internal revenue (defendant) denied IPC’s capital-construction-related depreciation deduction because the depreciation was a capital expenditure, which § 263(a)(1) of the tax code required to be computed over the useful life (30 years or more) of IPC’s new capital facilities. IPC petitioned the United States Tax Court for a redetermination. The tax court found for the commissioner, and the court of appeals reversed in favor of IPC. The United States Supreme Court granted certiorari.
Rule of Law
Holding and Reasoning (Blackmun, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 175,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 14,000 briefs, keyed to 188 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.