Legal Opinion
Johnson v. United States
United States Court of Claims
Decided September 26, 1986No. 310-84TPublishedCited by 15 opinions
1Opinion of the Court
OPINION
MAYER, Judge.
The questions presented in this case are whether the transaction for the sale and leaseback of computer equipment is a “sham” for tax purposes, and whether it qualifies under section 183 of the Internal Revenue Code of 1954 as an activity engaged in for profit.
Background
During the years 1979-81, plaintiffs William J. and Marie L. Johnson were married and residing in Goshen, Indiana. On January 2,1986, William J. Johnson died and his estate was substituted as co-plaintiff. Nevertheless, and because Marie L. Johnson is a party only because she signed joint income tax returns…
2Cases cited29 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Commissioner v. BrownSupreme Court of the United States · 1965
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
24 more not listed; retrieve them via the Exa API.
3Cited by15 opinions
- Rose v. CommissionerUnited States Tax Court · 1987
- Long Term Capital Holdings v. United StatesDistrict Court, D. Connecticut · 2004
- Keener v. United StatesUnited States Court of Federal Claims · 2007
- Consolidated Edison Co. v. United StatesUnited States Court of Federal Claims · 2009
- Transpac Drilling Venture v. United StatesUnited States Court of Federal Claims · 1995
10 more not listed; retrieve them via the Exa API.