Kansas City S. R. Co. v. Commissioner
United States Tax Court
Issue I. Carland Rentals: Petitioner claims that amounts paid or accrued pursuant to written agreements for the lease of equipment are deductible as rentals under sec. 162(a)(3), I.R.C. 1954. Held: The payments were for the "continued use or possession" of equipment used in the lessees' business, to which the lessees took no title and in which the lessees had no equity.
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Issue I. Carland Rentals: Petitioner claims that amounts paid or accrued pursuant to written agreements for the lease of equipment are deductible as rentals under sec. 162(a)(3), I.R.C. 1954. Held: The payments were for the "continued use or possession" of equipment used in the lessees' business, to which the lessees took no title and in which the lessees had no equity. As such, the payments are properly deductible under sec. 162(a)(3), I.R.C. 1954. Held, further, the amounts paid or accrued during the years at issue pursuant to the lease agreements constituted reasonable rentals. Issue II.…
1Opinion of the Court
The Kansas City Southern Railway Company, Petitioner v. Commissioner of Internal Revenue, Respondent; Kansas City Southern Industries, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Kansas City S. R. Co. v. Commissioner
Docket Nos. 971-72, 974-72, 4788-73
United States Tax Court
76 T.C. 1067; 1981 U.S. Tax Ct. LEXIS 104;
June 30, 1981, Filed
Decisions will be entered under Rule 155.
Issue I. Carland Rentals: Petitioner claims that amounts paid or accrued pursuant to written agreements for the lease of equipment are deductible as rentals under sec. 162(a)(3), I.R.C. 1954. Held: The…
2Cases cited53 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Commissioner v. BrownSupreme Court of the United States · 1965
- Fawcus MacHine Co. v. United StatesSupreme Court of the United States · 1931
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