Sprint Corp. v. Commissioner
United States Tax Court
P, a telephone company, purchased certain telecommunications equipment, digital switches, that required computer software to operate. P claimed investment tax credits (ITC) and depreciation deductions under the accelerated cost recovery system (ACRS) with respect to the total cost of each digital switch, which included the cost of the software used in each switch.
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P, a telephone company, purchased certain telecommunications equipment, digital switches, that required computer software to operate. P claimed investment tax credits (ITC) and depreciation deductions under the accelerated cost recovery system (ACRS) with respect to the total cost of each digital switch, which included the cost of the software used in each switch. R determined that P's expenditures allocable to the software did not qualify for the ITC or depreciation under the ACRS. P treated property known as "drop and block" as 5-year property, as defined in sec. 168(c) (2) (B), I.R.C. R…
1Opinion of the Court
SPRINT CORPORATION AND SUBSIDIARIES, F.K.A. UNITED TELECOMMUNICATIONS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sprint Corp. v. Commissioner
Docket No. 13159-94
United States Tax Court
108 T.C. 384; 1997 U.S. Tax Ct. LEXIS 17; 108 T.C. No. 19;
April 30, 1997, Filed
Decision will be entered under Rule 155.
P, a telephone company, purchased certain telecommunications equipment, digital switches, that required computer software to operate. P claimed investment tax credits (ITC) and depreciation deductions under the accelerated cost recovery system (ACRS) with respect to the…
Also in this document: Dissent · Colvin; Dissent · Korner.
2Cases cited18 opinions
- United States v. LudeySupreme Court of the United States · 1927
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- United States v. ScovilSupreme Court of the United States · 1955
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