Philadelphia Park Amusement Co. v. United States
United States Court of Claims
126 F.Supp. 184 (1954)
Relevant factsFree
Philadelphia Park (plaintiff) received a 10-year extension on a passenger-railway franchise from the city in exchange for deeding over Strawberry Bridge, which it had built; after abandoning the franchise by 1946, Philadelphia Park sought depreciation deductions based on the cost of the abandoned extension, and the Commissioner (defendant) disputed how that cost basis should be calculated.
IssueFree
Whether the cost basis of property received in a taxable exchange is the fair market value of the property received, rather than the value of the property given up.