Central De Gas De Chihuahua, S.A. v. Commissioner
United States Tax Court
P rented equipment to X which did not pay rent. P and X were under common control of Y, and respondent, acting under the authority of sec. 482, I.R.C., allocated to P the fair rental value of the equipment. Held, since sec. 881, I.R.C., does not require an actual payment, such fair rental value is income under that section.
1Opinion of the Court
CENTRAL DE GAS DE CHIHUAHUA, S.A., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Central De Gas De Chihuahua, S.A. v. Commissioner
Docket No. 18370-91
United States Tax Court
102 T.C. 515; 1994 U.S. Tax Ct. LEXIS 21; 102 T.C. No. 19;
April 4, 1994, Filed
P rented equipment to X which did not pay rent. P and X were under common control of Y, and respondent, acting under the authority of sec. 482, I.R.C., allocated to P the fair rental value of the equipment. Held, since sec. 881, I.R.C., does not require an actual payment, such fair rental value is income under that section.
George W.…
2Cases cited13 opinions
- Charles A. Sammons, Individually, and Estate of Rosine S. Sammons, Deceased, Charles A. Sammons, Independent v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1973
- Latham Park Manor, Inc. v. CommissionerUnited States Tax Court · 1977
- Casanova Co. v. CommissionerUnited States Tax Court · 1986
- R. T. French Co. v. CommissionerUnited States Tax Court · 1973
- Blanton v. CommissionerUnited States Tax Court · 1990
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