Bussing v. Commissioner
United States Tax Court
In our opinion reported at 88 T.C. 449 (1987), we disregarded Sutton's participation in a transaction between AG, the purported seller-lessee, and P, the purported buyer-lessor, of an interest in equipment subject to a security interest and long-term lease from a prior sale-leaseback transaction among AG, Continentale, and Handelsbank. Sutton purportedly bought the equipment from AG and sold it to P at the same closing.
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In our opinion reported at 88 T.C. 449 (1987), we disregarded Sutton's participation in a transaction between AG, the purported seller-lessee, and P, the purported buyer-lessor, of an interest in equipment subject to a security interest and long-term lease from a prior sale-leaseback transaction among AG, Continentale, and Handelsbank. Sutton purportedly bought the equipment from AG and sold it to P at the same closing. Further, we disregarded the long-term purchase money note between P and Sutton because the evidence failed to show any payments on the note. Finally, we held that P acquired…
1Opinion of the Court
SUPPLEMENTAL OPINION
WILLIAMS, Judge:
This case is before the Court on petitioners’ motion for reconsideration of the Court’s opinion pursuant to Rule 161, Tax Court Rules of Practice and Procedure. The Court’s opinion in this case, reported at 88 T.C. 449 (1987), was filed on February 23, 1987. Petitioners’ motion was timely filed on April 10, 1987.1
Petitioners ask that the Court reconsider our findings of fact and conclusions of law with respect to the following issues: (1) The function and role of Sutton Capital Corp. in the purchase and lease transaction at issue in this case; (2) the…
2Cases cited17 opinions
- Commissioner v. TowerSupreme Court of the United States · 1946
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Abramson v. CommissionerUnited States Tax Court · 1986
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- Gefen v. CommissionerUnited States Tax Court · 1986
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