Arevalo v. Comm'r
United States Tax Court
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…
Read the full summary
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
- Gregory v. HelveringSupreme Court of the United States · 1935
- Smith v. United StatesSupreme Court of the United States · 1993
- Corliss v. BowersSupreme Court of the United States · 1930
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- United States v. CaliforniaSupreme Court of the United States · 1936
11 more not listed; retrieve them via the Exa API.