Dinkins v. Commissioner
United States Tax Court
Rental (a subchapter S corporation) was engaged in the business of leasing or renting construction equipment. It was required, in its highly competitive business, to have modern types of equipment available and it was also necessary to keep available the kinds of equipment currently in demand. Since its inception in 1945 Rental regularly sold its rental equipment at a time when it had substantial resale value.
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Rental (a subchapter S corporation) was engaged in the business of leasing or renting construction equipment. It was required, in its highly competitive business, to have modern types of equipment available and it was also necessary to keep available the kinds of equipment currently in demand. Since its inception in 1945 Rental regularly sold its rental equipment at a time when it had substantial resale value. Held, useful lives of categories of equipment and salvage values for purposes of depreciation should be determined from Rental's past experience with respect to holding periods and…
1Opinion of the Court
Mulroney, Judge:
Respondent determined the following deficiencies in income tax:
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The issues are (1) whether Rental Equipment Co. used the proper useful lives and salvage values for its numerous units of equipment in determining a reasonable allowance for depreciation of such equipment during the years here involved, and (2) the amount of depreciation allowable on a unit of equipment in the year that unit was sold.
FINDINGS OF FACT
Some of the facts were stipulated and they are so found.
Thomas A. and Catherine F. Dinkins, husband and wife, are residents of St. Louis, Mo. They filed…
2Cases cited4 opinions
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Fribourg Navigation Co. v. CommissionerSupreme Court of the United States · 1966
- Robley H. Evans and Julia M. Evans v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1959
- Engineers, Ltd. Pipeline Co. v. CommissionerUnited States Tax Court · 1965
3Cited by7 opinions
- Coors v. CommissionerUnited States Tax Court · 1973
- Dinkins v. CommissionerCourt of Appeals for the Eighth Circuit · 1967
- Browning v. CommissionerUnited States Tax Court · 1988
- Medtronic, Inc. v. Comm'rUnited States Tax Court · 2016
- Catherine F. Dinkins v. Commissioner of Internal Revenue, Agnes Fabick v. Commissioner of Internal Revenue, Francis J. Fabick and Mildred Fabick v. Commissioner of Internal Revenue, John J. Fabick and Elaine Fabick v. Commissioner of Internal Revenue, Joseph G. Fabick and Gloria Fabick v. Commissioner of Internal Revenue, Gilbert E. McNeill and Loretta F. McNeill v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1967
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