Egizii v. Commissioner
United States Tax Court
Petitioners sought investment credits for portions of a warehouse they leased to their controlled corporation. Held, property required to have been manufactured or produced by lessors to qualify them as noncorporate lessors eligible for the credit is sec. 38, I.R.C. 1954, property subject to the lease, not entire property subject to the lease. Held, further, petitioners did not manufacture or produce the sec. 38 property subject to the lease.
1Opinion of the Court
John E. Egizii and Helen Egizii, Petitioners v. Commissioner of Internal Revenue, Respondent
Egizii v. Commissioner
Docket No. 30018-83
United States Tax Court
86 T.C. 450; 1986 U.S. Tax Ct. LEXIS 136; 86 T.C. No. 29;
March 25, 1986, Filed
Decision will be entered for the respondent.
Petitioners sought investment credits for portions of a warehouse they leased to their controlled corporation. Held, property required to have been manufactured or produced by lessors to qualify them as noncorporate lessors eligible for the credit is sec. 38, I.R.C. 1954, property subject to the lease, not entire…
2Cases cited7 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Ridder v. CommissionerUnited States Tax Court · 1981
- Lykes Bros. Steamship v. United StatesUnited States Court of Claims · 1975
- Laurence M. And Phyllis W. Carlson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Anesthesia Service Medical Group, Inc. v. CommissionerUnited States Tax Court · 1985
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