Legal Opinion

East Coast Equipment Co. v. Commissioner

United States Tax Court

Decided October 22, 1953No. Docket No. 30984Published

1. The petitioner, who was engaged in the trade or business of selling construction equipment, entered into 26 "equipment rental agreements," together with purchase options which gave the purported lessee the right to purchase the equipment at the end of the lease for a consideration amounting to the downpayment and the installments required in the rental agreement and provided further that the "rental payments" should apply to the purchase price.

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1. The petitioner, who was engaged in the trade or business of selling construction equipment, entered into 26 "equipment rental agreements," together with purchase options which gave the purported lessee the right to purchase the equipment at the end of the lease for a consideration amounting to the downpayment and the installments required in the rental agreement and provided further that the "rental payments" should apply to the purchase price. To secure performance from the lessee, interest-bearing notes were required by the petitioner. These notes, together with the contracts and…

1Opinion of the Court

East Coast Equipment Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

East Coast Equipment Co. v. Commissioner

Docket No. 30984

United States Tax Court

21 T.C. 112; 1953 U.S. Tax Ct. LEXIS 43;

October 22, 1953, Promulgated

Decision will be entered under Rule 50.

1. The petitioner, who was engaged in the trade or business of selling construction equipment, entered into 26 "equipment rental agreements," together with purchase options which gave the purported lessee the right to purchase the equipment at the end of the lease for a consideration amounting to the downpayment and the…

2Cases cited5 opinions

  1. Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
  2. Woody v. CommissionerUnited States Tax Court · 1952
  3. Elmer v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1933
  4. Lanova Corp. v. Comm'rUnited States Tax Court · 1952
  5. East Coast Equipment Co. v. CommissionerUnited States Tax Court · 1953

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