Carland, Inc. v. Commissioner
United States Tax Court
Petitioner was engaged in the business of leasing various categories of tangible property, predominantly railroad rolling stock, under fixed-term leases. Petitioner employed the income-forecast method keyed to the lease terms to compute the depreciation allowance under the statute for the leased assets.
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Petitioner was engaged in the business of leasing various categories of tangible property, predominantly railroad rolling stock, under fixed-term leases. Petitioner employed the income-forecast method keyed to the lease terms to compute the depreciation allowance under the statute for the leased assets. Held: 1. Petitioner's use of the income-forecast method to compute a reasonable allowance for depreciation under sec. 167, I.R.C. 1954, is inappropriate under the circumstances of this case. Petitioner is entitled to employ the double-declining-balance method under sec. 167(b) to compute the…
1Opinion of the Court
OPINION
DRENNEN, Judge:
This case was assigned for trial or other disposition to Special Trial Judge James M. Gussis pursuant to section 7456(d) (redesignated section 7443A(b) by section 1556 of the Tax Reform Act of 1986, Pub. L. 99-514, 100 Stat. 2755) and Rule 180 et seq.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
GUSSIS, Special Trial Judge: Respondent determined the following deficiencies in petitioner’s Federal income taxes:
Income tax
deficiency TYE Dec. 31-
$24,623.61 1970
41,798.86 1971
TYE Dec.…
2Cases cited25 opinions
- Helvering v. National Grocery Co.Supreme Court of the United States · 1938
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Commissioner v. Idaho Power Co.Supreme Court of the United States · 1974
- Siegel v. CommissionerUnited States Tax Court · 1982
- Abramson v. CommissionerUnited States Tax Court · 1986
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3Cited by12 opinions
- Zarin v. CommissionerUnited States Tax Court · 1989
- Campbell v. CommissionerUnited States Tax Court · 1990
- Abc Rentals Of San Antonio, Inc. v. Commissioner Of Internal RevenueCourt of Appeals for the Tenth Circuit · 1998
- ABC Rentals of San Antonio, Inc. v. CommissionerCourt of Appeals for the Tenth Circuit · 1998
- Carland, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1990
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