Bloomberg v. Commissioner
United States Tax Court
1. Petitioner purchased medical equipment and furnishings in 1974 which he immediately leased to a corporation of which he was an employee under a written lease dated Aug. 1, 1974, with a term of 5 years. The property had estimated useful lives of 5 to 7 years. The lease was purportedly canceled on June 10, 1977, prior to the expiration of 50 percent of the useful lives of the property.
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1. Petitioner purchased medical equipment and furnishings in 1974 which he immediately leased to a corporation of which he was an employee under a written lease dated Aug. 1, 1974, with a term of 5 years. The property had estimated useful lives of 5 to 7 years. The lease was purportedly canceled on June 10, 1977, prior to the expiration of 50 percent of the useful lives of the property. Held, cancellation of the lease does not permit petitioner to meet the conditions of sec. 46(e)(3), I.R.C. 1954, for allowance of an investment credit with respect to the property. 2. Petitioner purchased two…
1Opinion of the Court
Drennen, Judge:
Respondent determined a deficiency in petitioners’ income tax for the year 1974 in the amount of $6,849.33. Due to concessions of the parties, the only issues for decision are (1) whether petitioners are entitled to an investment credit under sections 38 and 46, I.R.C. 1954, for equipment owned by petitioners and leased to petitioners’ professional corporation, Leroy Bloomberg, M.D., Inc., and (2) whether petitioners are entitled to an investment credit in excess of $65.86 for two automobiles owned by them and purportedly used by them in their business as employees of Leroy…
2Cases cited2 opinions
- World Airways, Inc. v. CommissionerUnited States Tax Court · 1974
- Gordon v. CommissionerUnited States Tax Court · 1978
3Cited by26 opinions
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Ridder v. CommissionerUnited States Tax Court · 1981
- Ragnar v. Hokanson and Marilyn L. Hokanson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- O. Robert Freesen v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1986
- MANNING v. COMMISSIONERUnited States Tax Court · 1993
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