U.S. Bancorp and Its Consolidated Subsidiaries v. Commissioner
United States Tax Court
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
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
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