Legal Opinion

Holder Driv-Ur-Self, Inc. v. Commissioner

United States Tax Court

Decided November 20, 1964No. Docket No. 91372Published

Petitioner is engaged in the automobile-leasing business. Each of the automobiles used by petitioner in its business during the period here involved had a useful life of 2 years and a salvage value of 50 percent of petitioner's cost. Held: 1. Petitioner is not entitled to use the declining-balance method of depreciation because the useful life of its vehicles is less than 3 years. 2. Petitioner is entitled to depreciate its vehicles in the year of sale below the resale price.

1Opinion of the Court

Holder Driv-Ur-Self, Inc., Petitioner, v. Commissioner of Internal Revenue, Respondent

Holder Driv-Ur-Self, Inc. v. Commissioner

Docket No. 91372

United States Tax Court

43 T.C. 202; 1964 U.S. Tax Ct. LEXIS 17;

November 20, 1964, Filed November 20, 1964, Filed

Decision will be entered under Rule 50.

Petitioner is engaged in the automobile-leasing business. Each of the automobiles used by petitioner in its business during the period here involved had a useful life of 2 years and a salvage value of 50 percent of petitioner's cost. Held:

1. Petitioner is not entitled to use the declining-balance method…

2Cases cited8 opinions

  1. Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
  2. Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
  3. Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
  4. Hertz Corp. v. United StatesSupreme Court of the United States · 1960
  5. Shainberg v. CommissionerUnited States Tax Court · 1959

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