Legal Opinion

Cooper v. Commissioner

United States Tax Court

Decided January 13, 1987No. Docket Nos. 5317-83, 6450-83, 8352-83, 8798-83, 9677-83, 29230-83, 34818-83, 529-84, 25826-84Published

Ps purchased solar water heating systems, on a leveraged basis, from Bliss; thereafter, pursuant to a prearranged agreement, Ps leased the systems to Coordinated for a term of 7 years. Coordinated subleased the systems to homeowners. Included in Ps' lease agreement with Coordinated was an option whereby Ps could require Coordinated to purchase the systems upon the expiration of the lease for an amount not less than the balance still owed on the notes to Bliss.

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Ps purchased solar water heating systems, on a leveraged basis, from Bliss; thereafter, pursuant to a prearranged agreement, Ps leased the systems to Coordinated for a term of 7 years. Coordinated subleased the systems to homeowners. Included in Ps' lease agreement with Coordinated was an option whereby Ps could require Coordinated to purchase the systems upon the expiration of the lease for an amount not less than the balance still owed on the notes to Bliss. Bliss guaranteed Coordinated's obligations under the leases. Held: Ps entered into the transactions with a bona fide objective to make…

1Opinion of the Court

Richard G. Cooper and June A. Cooper, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Cooper v. Commissioner

Docket Nos. 5317-83, 6450-83, 8352-83, 8798-83, 9677-83, 29230-83, 34818-83, 529-84, 25826-84

United States Tax Court

88 T.C. 84; 1987 U.S. Tax Ct. LEXIS 6; 88 T.C. No. 6;

January 13, 1987. January 13, 1987, Filed

Decisions will be entered under Rule 155.

Ps purchased solar water heating systems, on a leveraged basis, from Bliss; thereafter, pursuant to a prearranged agreement, Ps leased the systems to Coordinated for a term of 7 years. Coordinated subleased the systems…

2Cases cited53 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Gregory v. HelveringSupreme Court of the United States · 1935
  3. Spies v. United StatesSupreme Court of the United States · 1943
  4. Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
  5. Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978

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