Coleman v. Commissioner
United States Tax Court
Petitioners purchased an interest in certain computer equipment from C, which had purchased such interest from E, which had purchased an interest in the equipment from A. Petitioners then leased their interest back to C. Held, petitioners did not have a depreciable interest in the equipment during the years in issue. Held, further, interest payments on petitioners' nonrecourse note, which does not constitute genuine indebtedness, are not deductible.
Read the full summary
Petitioners purchased an interest in certain computer equipment from C, which had purchased such interest from E, which had purchased an interest in the equipment from A. Petitioners then leased their interest back to C. Held, petitioners did not have a depreciable interest in the equipment during the years in issue. Held, further, interest payments on petitioners' nonrecourse note, which does not constitute genuine indebtedness, are not deductible. Held, further, interest payments on a recourse note are deductible.
1Opinion of the Court
Ronald Coleman and Nancy Coleman, Petitioners v. Commissioner of Internal Revenue, Respondent
Coleman v. Commissioner
Docket No. 7216-83
United States Tax Court
87 T.C. 178; 1986 U.S. Tax Ct. LEXIS 75; 87 T.C. No. 12;
July 23, 1986, Filed
Decision will be entered under Rule 155.
Petitioners purchased an interest in certain computer equipment from C, which had purchased such interest from E, which had purchased an interest in the equipment from A. Petitioners then leased their interest back to C. Held, petitioners did not have a depreciable interest in the equipment during the years in issue. Held,…
2Cases cited49 opinions
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- E.A. Brannen and Frances K. Brannen v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 1984
- Brannen v. CommissionerUnited States Tax Court · 1982
44 more not listed; retrieve them via the Exa API.