Larsen v. Commissioner
United States Tax Court
P, an individual, entered into four separate transactions with F concerning the sale and leaseback of certain computer equipment. Each transaction, individually identified as the A, H, IRV 1, or IRV 2 transaction, was subject to prior leases between F and certain end-users. The purchase price of each transaction was paid with a recourse note and a nonrecourse installment note.
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P, an individual, entered into four separate transactions with F concerning the sale and leaseback of certain computer equipment. Each transaction, individually identified as the A, H, IRV 1, or IRV 2 transaction, was subject to prior leases between F and certain end-users. The purchase price of each transaction was paid with a recourse note and a nonrecourse installment note. Each purchase agreement required that P assume a certain portion of nonrecourse indebtedness incurred by F to acquire the equipment. Such assumption by P did not increase the amount of the purchase price. The assumed…
1Opinion of the Court
HAMBLEN, Judge:
Respondent determined deficiencies in petitioners’1 Federal income tax as follows:
Year Deficiency
1979. $33,087
1980. 55,280
The primary issues for our determination are whether petitioner’s transactions with respect to certain computer equipment were structured as a tax-avoidance scheme devoid of economic substance which should be disregarded for Federal income tax purposes, and whether petitioner acquired the benefits and burdens of ownership. Subsidiary issues for our determination are (1) whether the ownership interest acquired, if any, was a present depreciable interest; (2)…
2Cases cited45 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
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3Cited by90 opinions
- Howard Gilman v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1991
- Levy v. CommissionerUnited States Tax Court · 1988
- Casebeer v. CommissionerCourt of Appeals for the Ninth Circuit · 1990
- LaVerne v. CommissionerUnited States Tax Court · 1990
- Winn-Dixie Stores v. Comm'rUnited States Tax Court · 1999
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