U.S. Bancorp v. Commissioner
United States Tax Court
P, a bank holding company, leased a mainframe computer from ICC, a finance corporation, for a 5-year term. Less than 1 year later, P decided that the computer was no longer adequate for its needs. P thereupon entered into a "rollover agreement" with ICC, whereby the lease was terminated upon the condition, among other things, that P commit to finance the replacement equipment with ICC.
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P, a bank holding company, leased a mainframe computer from ICC, a finance corporation, for a 5-year term. Less than 1 year later, P decided that the computer was no longer adequate for its needs. P thereupon entered into a "rollover agreement" with ICC, whereby the lease was terminated upon the condition, among other things, that P commit to finance the replacement equipment with ICC. The rollover agreement provided for a $ 2.5 million rollover charge to be paid by P. Shortly thereafter, pursuant to the rollover agreement, P leased a more powerful mainframe computer from ICC for a 5-year…
1Opinion of the Court
U.S. BANCORP AND ITS CONSOLIDATED SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
U.S. Bancorp v. Commissioner
Tax Ct. Dkt. No. 27342-96. Docket No. 27342-96.1
United States Tax Court
111 T.C. 231; 1998 U.S. Tax Ct. LEXIS 47; 111 T.C. No. 10;
September 21, 1998, Filed
P, a bank holding company, leased a mainframe computer from ICC, a finance corporation, for a 5-year term. Less than 1 year later, P decided that the computer was no longer adequate for its needs. P thereupon entered into a "rollover agreement" with ICC, whereby the lease was terminated upon the condition,…
2Cases cited24 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Deputy, Administratrix v. Du PontSupreme Court of the United States · 1940
- Indopco, Inc. v. CommissionerSupreme Court of the United States · 1992
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
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