East Coast Equipment Co. v. Commissioner
United States Tax Court
1. The petitioner, who was engaged in the trade or business of selling construction equipment, entered into 26 "equipment rental agreements," together with purchase options which gave the purported lessee the right to purchase the equipment at the end of the lease for a consideration amounting to the downpayment and the installments required in the rental agreement and provided further that the "rental payments" should apply to the purchase price.
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1. The petitioner, who was engaged in the trade or business of selling construction equipment, entered into 26 "equipment rental agreements," together with purchase options which gave the purported lessee the right to purchase the equipment at the end of the lease for a consideration amounting to the downpayment and the installments required in the rental agreement and provided further that the "rental payments" should apply to the purchase price. To secure performance from the lessee, interest-bearing notes were required by the petitioner. These notes, together with the contracts and…
1Opinion of the Court
OPINION.
Hill, Judge:
During the taxable years 1946 and 1947 the petitioner, which was engaged in the trade or business of selling construction equipment, entered into 26 agreements. Each of these agreements was captioned “Equipment Rental Agreement.” Simultaneously with the execution of these agreements, the petitioner and the purported lessee executed a purchase option covering the same property included in the rental agreement.
The petitioner contends that the transactions in controversy accomplished no more than the rental of the construction equipment involved and that the exercise of the…
2Cases cited4 opinions
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Woody v. CommissionerUnited States Tax Court · 1952
- Elmer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1933
- Lanova Corp. v. Comm'rUnited States Tax Court · 1952
3Cited by2 opinions
- East Coast Equipment Company v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1955
- East Coast Equipment Co. v. CommissionerUnited States Tax Court · 1953