Legal Opinion
ABC Rentals of San Antonio, Inc. v. Commissioner
Court of Appeals for the Tenth Circuit
Decided September 27, 1996No. 95-9008 to 95-9010PublishedCited by 5 opinions
1Opinion of the Court
BRISCOE, Circuit Judge.
In these consolidated appeals, we decide whether the rent-to-own industry may properly depreciate its inventory for tax purposes using the income forecast method rather than the Modified Accelerated Cost Recovery System (MACRS) under I.R.C. § 168(f)(1). The Tax Court held that appellants’ rent-to-own inventory was not properly depreciable under the income forecast method, and thus upheld the Commissioner’s notice of deficiency. We reverse and remand for further proceedings.
Based on our analysis of the statutory language and legislative history, we conclude that §…
2Cases cited24 opinions
- Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc.Supreme Court of the United States · 1984
- United States v. Ron Pair Enterprises, Inc.Supreme Court of the United States · 1989
- Rowland v. California Men's Colony, Unit II Men's Advisory CouncilSupreme Court of the United States · 1993
- Central Bank of Denver, N. A. v. First Interstate Bank of Denver, N. A.Supreme Court of the United States · 1994
- Commissioner v. Glenshaw Glass Co.Supreme Court of the United States · 1955
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3Cited by5 opinions
- First Chicago Nbd Corporation v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1998
- Kornfeld v. CommissionerCourt of Appeals for the Tenth Circuit · 1998
- Johnston v. CommissionerCourt of Appeals for the Tenth Circuit · 1997
- Frederick D. Doe, Barbara L. Doe, David S. Lamure, Margaret C. Lamure, James E. Lankford, Virginia Lankford v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1997
- ABC Rentals of San Antonio, Inc. v. CommissionerCourt of Appeals for the Tenth Circuit · 1996