Legal Opinion

Arevalo v. Comm'r

United States Tax Court

Decided May 18, 2005No. 13272-04Published

P entered into a contract with American Telecommunications Co., Inc. (ATC). Under the terms of the contract, P paid $ 10,000 to ATC and ATC provided P with legal title to two pay telephones (pay phones). P also entered into a service agreement with Alpha Telcom, Inc. (Alpha Telcom), the parent company of ATC, under which Alpha Telcom serviced the pay phones and retained most of the profits. 1. Held: Because P did not have the benefits and burdens of ownership with respect to…

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P entered into a contract with American Telecommunications Co., Inc. (ATC). Under the terms of the contract, P paid $ 10,000 to ATC and ATC provided P with legal title to two pay telephones (pay phones). P also entered into a service agreement with Alpha Telcom, Inc. (Alpha Telcom), the parent company of ATC, under which Alpha Telcom serviced the pay phones and retained most of the profits. 1. Held: Because P did not have the benefits and burdens of ownership with respect to the pay phones, P did not have a depreciable interest in the pay phones. Therefore, P is not entitled to claim a…

1Opinion of the Court

EDWARD R. AREVALO, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Arevalo v. Comm'r

No. 13272-04

United States Tax Court

124 T.C. 244; 2005 U.S. Tax Ct. LEXIS 16; 124 T.C. No. 15;

May 18, 2005, Filed

P entered into a contract with American Telecommunications

Co., Inc. (ATC). Under the terms of the contract, P paid $ 10,000

to ATC and ATC provided P with legal title to two pay telephones

(pay phones). P also entered into a service agreement with Alpha

Telcom, Inc. (Alpha Telcom), the parent company of ATC, under

which Alpha Telcom serviced the pay phones and retained most of

the profits.

1.…

2Cases cited16 opinions

  1. Gregory v. HelveringSupreme Court of the United States · 1935
  2. Smith v. United StatesSupreme Court of the United States · 1993
  3. Corliss v. BowersSupreme Court of the United States · 1930
  4. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
  5. United States v. CaliforniaSupreme Court of the United States · 1936

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