Kansas City S. R. Co. v. Commissioner
United States Tax Court
Issue I. Carland Rentals: Petitioner claims that amounts paid or accrued pursuant to written agreements for the lease of equipment are deductible as rentals under sec. 162(a)(3), I.R.C. 1954. Held: The payments were for the "continued use or possession" of equipment used in the lessees' business, to which the lessees took no title and in which the lessees had no equity.
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Issue I. Carland Rentals: Petitioner claims that amounts paid or accrued pursuant to written agreements for the lease of equipment are deductible as rentals under sec. 162(a)(3), I.R.C. 1954. Held: The payments were for the "continued use or possession" of equipment used in the lessees' business, to which the lessees took no title and in which the lessees had no equity. As such, the payments are properly deductible under sec. 162(a)(3), I.R.C. 1954. Held, further, the amounts paid or accrued during the years at issue pursuant to the lease agreements constituted reasonable rentals. Issue II.…
1Opinion of the Court
Drennen, Judge:
These consolidated cases were tried before Special Trial Judge Charles R. Johnston pursuant to Rules 180 and 182, Tax Court Rules of Practice and Procedure. His report was filed on February 1,1980, and exceptions to the report were subsequently filed by the parties. The Court has duly considered those exceptions and has given appropriate weight to the findings of fact and conclusions of law recommended by Special Trial Judge Johnston. See Rule 182(c) and (d), and the accompanying Note, Tax Court Rules of Practice and Procedure, 60 T.C. 1057,1149-1150 (1973).
Respondent…
2Cases cited52 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Commissioner v. BrownSupreme Court of the United States · 1965
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
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3Cited by31 opinions
- Estate of Thomas v. CommissionerUnited States Tax Court · 1985
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- Consolidated Edison Co. v. United StatesUnited States Court of Federal Claims · 2009
- Feldman v. CommissionerUnited States Tax Court · 1985
- Kansas City S. Indus. v. CommissionerUnited States Tax Court · 1992
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