Norfolk Southern Corp. v. Commissioner
United States Tax Court
Ps claimed investment tax credit (ITC) on their 1981 consolidated Federal income tax return and accelerated depreciation deductions on their 1981 through 1985 consolidated Federal income tax returns.
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Ps claimed investment tax credit (ITC) on their 1981 consolidated Federal income tax return and accelerated depreciation deductions on their 1981 through 1985 consolidated Federal income tax returns. The ITC and depreciation related to certain intermodal cargo containers (containers) included under a safe harbor lease agreement entered into with F on Nov. 13, 1981, pursuant to sec. 168(f)(8), I.R.C.Sec. 48(a)(2)(A), I.R.C., generally excludes property used predominantly outside the United States from "eligible section 38 property". Sec. 48(a)(2)(B)(v), I.R.C., excepts from sec. 48(a)(2)(A),…
1Opinion of the Court
Norfolk Southern Corporation and Affiliated Companies, Petitioners v. Commissioner of Internal Revenue, Respondent
Norfolk Southern Corp. v. Commissioner
Docket Nos. 19305-91, 19306-91
United States Tax Court
104 T.C. 13; 1995 U.S. Tax Ct. LEXIS 2; 104 T.C. No. 2;
January 11, 1995, Filed
Decisions will be entered under Rule 155.
Ps claimed investment tax credit (ITC) on their 1981 consolidated Federal income tax return and accelerated depreciation deductions on their 1981 through 1985 consolidated Federal income tax returns. The ITC and depreciation related to certain intermodal cargo containers…
2Cases cited106 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Richards v. United StatesSupreme Court of the United States · 1962
- Dewsnup v. TimmSupreme Court of the United States · 1992
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