Legal Opinion

Estate of Delman v. Commissioner

United States Tax Court

Decided October 9, 1979No. Docket No. 6220-77Published

Equipment Leasing, in which petitioners were general partners, purchased equipment for a price of $ 1,284,612 by nonrecourse financing.

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Equipment Leasing, in which petitioners were general partners, purchased equipment for a price of $ 1,284,612 by nonrecourse financing. When the equipment was subsequently repossessed, its fair market value was $ 400,000, Equipment Leasing's adjusted basis in the property was $ 504,625.80, and the outstanding balance of the nonrecourse financing was $ 1,182,542.07. Held, the gain realized by Equipment Leasing upon the repossession was the amount by which the balance of the nonrecourse financing exceeded the adjusted basis. Held, further, under sec. 1245, I.R.C. 1954, the gain realized is…

1Opinion of the Court

Estate of Jerrold Delman, Deceased, Sidney Peilte, Administrator, et al., 1 Petitioners v. Commissioner of Internal Revenue, Respondent

Estate of Delman v. Commissioner

Docket No. 6220-77

United States Tax Court

73 T.C. 15; 1979 U.S. Tax Ct. LEXIS 43;

October 9, 1979, Filed

Decision will be entered for the respondent.

Equipment Leasing, in which petitioners were general partners, purchased equipment for a price of $ 1,284,612 by nonrecourse financing. When the equipment was subsequently repossessed, its fair market value was $ 400,000, Equipment Leasing's adjusted basis in the property was $…

2Cases cited42 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Crane v. CommissionerSupreme Court of the United States · 1947
  3. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  4. Helvering v. HammelSupreme Court of the United States · 1941
  5. Alice Phelan Sullivan Corporation, a California Corporation v. The United StatesUnited States Court of Claims · 1967

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