Western Contracting Corp. v. Commissioner
United States Tax Court
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.
Read the full summary
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
- United States v. LudeySupreme Court of the United States · 1927
- Heryford v. DavisSupreme Court of the United States · 1880
- Mills v. CommissionerUnited States Tax Court · 1948
- Bowen v. CommissionerUnited States Tax Court · 1949
- Bullock v. CommissionerUnited States Tax Court · 1956
10 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Western Contracting Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1959