Borgic v. Commissioner
United States Tax Court
Petitioners incorporated their farm operation in 1974. At that time, they transferred some property to the corporation but retained ownership of certain farm equipment. Petitioners entered into an agreement with the corporation whereby they would lease that equipment and any subsequently acquired farm equipment to the corporation for use in the business. Petitioners claimed investment tax credits for these assets.
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Petitioners incorporated their farm operation in 1974. At that time, they transferred some property to the corporation but retained ownership of certain farm equipment. Petitioners entered into an agreement with the corporation whereby they would lease that equipment and any subsequently acquired farm equipment to the corporation for use in the business. Petitioners claimed investment tax credits for these assets. In 1979, they transferred the farm equipment to the corporation. Held, the transfer of the farm equipment to the corporation constituted a mere change in form of conducting a trade…
1Opinion of the Court
Erval J. Borgic and Betty Borgic, Petitioners v. Commissioner of Internal Revenue, Respondent
Borgic v. Commissioner
Docket No. 288-84
United States Tax Court
86 T.C. 643; 1986 U.S. Tax Ct. LEXIS 124; 86 T.C. No. 40;
April 14, 1986, Filed
Decision will be entered for the petitioners.
Petitioners incorporated their farm operation in 1974. At that time, they transferred some property to the corporation but retained ownership of certain farm equipment. Petitioners entered into an agreement with the corporation whereby they would lease that equipment and any subsequently acquired farm equipment to the…
2Cases cited8 opinions
- Laurence M. And Phyllis W. Carlson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Carlson v. CommissionerUnited States Tax Court · 1982
- Charles L. Long and Ruth S. Long v. United StatesCourt of Appeals for the Sixth Circuit · 1981
- Ramm v. CommissionerUnited States Tax Court · 1979
- Baker v. United StatesDistrict Court, W.D. Texas · 1975
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