Legal Opinion

U.S. Bancorp and Its Consolidated Subsidiaries v. Commissioner

United States Tax Court

Decided September 21, 1998No. 27342-96Unknown

1Opinion of the Court

111 T.C. No. 10

UNITED STATES TAX COURT U.S. BANCORP AND ITS CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 27342-96.1 Filed September 21, 1998. P, a bank holding company, leased a mainframe computer from ICC, a finance corporation, for a 5-year term. Less than 1 year later, P decided that the computer was no longer adequate for its needs. P thereupon entered into a “rollover agreement” with ICC, whereby the lease was terminated upon the condition, among other things, that P commit to finance the 1 On Nov. 18, 1997, the Court granted…

2Cases cited24 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
  3. Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
  4. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  5. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992

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