Legal Opinion
Carolina, Clinchfield and Ohio Railway Company v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided July 10, 1987No. 1204, Docket 87-4003PublishedCited by 8 opinions
1Per curiam
Carolina, Clinchfield and Ohio Railway Company (“CC & 0”) appeals from a decision of the United States Tax Court (Richard C. Wilbur, Judge) determining deficiencies in its federal income taxes of approximately $1,066,000 for the taxable years 1972 through 1975. 82 T.C. 888 (1984). The principal issues concern the tax consequences of a 999-year lease between CC & O as lessor and two other railroads, Atlantic Coast Line Railroad Company and Louisville & Nashville Railroad Company, as lessees.
The term of the lease began in 1923. CC & O leased all of its railroad properties to the lessees. The…
2Cases cited2 opinions
- Great Western Power Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
- Carolina, C. & O. R. Co. v. CommissionerUnited States Tax Court · 1984
3Cited by8 opinions
- Kansas City S. Indus. v. CommissionerUnited States Tax Court · 1992
- Sol Lessinger and Edith Lessinger v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1989
- Jelle v. CommissionerUnited States Tax Court · 2001
- Belitsky v. CommissionerUnited States Tax Court · 1991
- Dennis and Dorinda J. Jelle v. CommissionerUnited States Tax Court · 2001
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