Legal Opinion

Western Contracting Corp. v. Commissioner

United States Tax Court

Decided April 30, 1958No. Docket No. 55906UnpublishedCited by 1 opinion

A corporation purported to lease 93 pieces of heavy construction equipment for varying terms of up to 28 months. The so-called leases were immediately assigned to one bank and all payments by the corporation were made to the bank. At the end of the so-called lease term, the dealers purportedly sold this equipment to the corporation.

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A corporation purported to lease 93 pieces of heavy construction equipment for varying terms of up to 28 months. The so-called leases were immediately assigned to one bank and all payments by the corporation were made to the bank. At the end of the so-called lease term, the dealers purportedly sold this equipment to the corporation. In each case, the sales price was the difference between the so-called rent and the list price at the beginning of the alleged lease term plus bank finance charges. The equipment was then depreciated over varying terms of from 4 to 8 years. Held, that the…

1Opinion of the Court

Western Contracting Corporation v. Commissioner.

Western Contracting Corp. v. Commissioner

Docket No. 55906.

United States Tax Court

T.C. Memo 1958-77; 1958 Tax Ct. Memo LEXIS 149; 17 T.C.M. (CCH) 371; T.C.M. (RIA) 58077;

April 30, 1958

A corporation purported to lease 93 pieces of heavy construction equipment for varying terms of up to 28 months. The so-called leases were immediately assigned to one bank and all payments by the corporation were made to the bank. At the end of the so-called lease term, the dealers purportedly sold this equipment to the corporation. In each case, the sales price was…

2Cases cited15 opinions

  1. United States v. LudeySupreme Court of the United States · 1927
  2. Heryford v. DavisSupreme Court of the United States · 1880
  3. Mills v. CommissionerUnited States Tax Court · 1948
  4. Bowen v. CommissionerUnited States Tax Court · 1949
  5. Bullock v. CommissionerUnited States Tax Court · 1956

10 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Western Contracting Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1959

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