Honeywell, Inc. v. Commissioner
United States Tax Court
P manufactured, leased, and sold computers and reported depreciation under the Class Life Asset Depreciation Range system described in sec. 1.167(a)-11(d)(3), Income Tax Regs. Literally applying the regulations, P reported sales of leased computers as credits to its depreciation reserve until the appropriate vintage account balance was exceeded, thereby delaying realization of income from sales.
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P manufactured, leased, and sold computers and reported depreciation under the Class Life Asset Depreciation Range system described in sec. 1.167(a)-11(d)(3), Income Tax Regs. Literally applying the regulations, P reported sales of leased computers as credits to its depreciation reserve until the appropriate vintage account balance was exceeded, thereby delaying realization of income from sales. R determined that computers held for sale and/or lease were "dual purpose property" not covered by his regulations. Held, P correctly reported income from sales of computers. P's subsidiary issued…
1Opinion of the Court
Honeywell Inc. and Subsidiaries, Petitioner v. Commissioner of Internal Revenue, Respondent
Honeywell, Inc. v. Commissioner
Docket No. 15807-83
United States Tax Court
87 T.C. 624; 1986 U.S. Tax Ct. LEXIS 49; 87 T.C. No. 37;
September 22, 1986, Filed
P manufactured, leased, and sold computers and reported depreciation under the Class Life Asset Depreciation Range system described in sec. 1.167(a)-11(d)(3), Income Tax Regs. Literally applying the regulations, P reported sales of leased computers as credits to its depreciation reserve until the appropriate vintage account balance was exceeded,…
2Cases cited17 opinions
- Rowan Cos. v. United StatesSupreme Court of the United States · 1981
- Hanover Bank v. CommissionerSupreme Court of the United States · 1962
- Commissioner v. BilderSupreme Court of the United States · 1962
- Helvering v. Union Pacific RailroadSupreme Court of the United States · 1934
- Cullinan v. Walker, Collector of Internal RevenueSupreme Court of the United States · 1923
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