Sprint Corp. v. Commissioner
United States Tax Court
P, a telephone company, purchased certain telecommunications equipment, digital switches, that required computer software to operate. P claimed investment tax credits (ITC) and depreciation deductions under the accelerated cost recovery system (ACRS) with respect to the total cost of each digital switch, which included the cost of the software used in each switch.
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P, a telephone company, purchased certain telecommunications equipment, digital switches, that required computer software to operate. P claimed investment tax credits (ITC) and depreciation deductions under the accelerated cost recovery system (ACRS) with respect to the total cost of each digital switch, which included the cost of the software used in each switch. R determined that P's expenditures allocable to the software did not qualify for the ITC or depreciation under the ACRS. P treated property known as "drop and block" as 5-year property, as defined in sec. 168(c) (2) (B), I.R.C. R…
1Opinion of the Court
Halpern, Judge:
Respondent determined deficiencies in petitioner’s Federal income taxes for the years and in the amounts as follows:
Year Deficiency
1982 . $7,400,722
1983 . 39,996
1984 . 318,791
1985 . 157,987
Sprint Corp. (Sprint or petitioner) is a Kansas corporation with its principal office in Westwood, Kansas. Formerly known as United Telecommunications, Inc., petitioner officially changed its name to Sprint Corp. as of February 26, 1992. Unless otherwise noted, references herein to Sprint and petitioner will include the period during which petitioner was known as United Telecommunications,…
2Cases cited15 opinions
- United States v. LudeySupreme Court of the United States · 1927
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- United States v. ScovilSupreme Court of the United States · 1955
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