Santulli v. Commissioner
United States Tax Court
These cases involve two similar transactions: A leasing company purchased equipment with funds borrowed from a bank. The leasing company leased the equipment to an end-user. Rent payments to be received from the end-user were assigned to the bank as security for the loan.
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These cases involve two similar transactions: A leasing company purchased equipment with funds borrowed from a bank. The leasing company leased the equipment to an end-user. Rent payments to be received from the end-user were assigned to the bank as security for the loan. The leasing company then sold the equipment to a middle company, which, in turn, sold the equipment to P. With regard to both of those sales, substantially all of the purchase price was evidenced by a long-term note and the equipment was acquired subject to both the lease to the end-user and the security interest of the…
1Opinion of the Court
RICHARD SANTULLI AND VIRGINIA SANTULLI, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Santulli v. Commissioner
Docket Nos. 24495-89, 16527-93.
United States Tax Court
T.C. Memo 1995-458; 1995 Tax Ct. Memo LEXIS 455; 70 T.C.M. (CCH) 801;
September 26, 1995, Filed
Decisions will be entered under Rule 155.
These cases involve two similar transactions: A leasing company purchased equipment with funds borrowed from a bank. The leasing company leased the equipment to an end-user. Rent payments to be received from the end-user were assigned to the bank as security for the loan. The leasing…
2Cases cited14 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Pallottini v. CommissionerUnited States Tax Court · 1988
- Metra Chem Corp. v. CommissionerUnited States Tax Court · 1987
- Emmons v. CommissionerUnited States Tax Court · 1989
- Gary M. Emmons and Martha C. Emmons v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1990
9 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Estate of Bradley v. CommissionerUnited States Tax Court · 1997