AMERCO v. Commissioner
United States Tax Court
During petitioner's fiscal year ended Mar. 31, 1973, owners of U-Haul trailers, trucks, handtrucks, and towbars executed "Investment Incentive Tax Credit Lessors Election Statements," electing as lessors to pass through the investment tax credit on such equipment to U-Haul International as lessee. Petitioner and U-Haul International filed a consolidated tax return for the fiscal year ended Mar. 31, 1973, claiming the investment tax credit covered by the elections.
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During petitioner's fiscal year ended Mar. 31, 1973, owners of U-Haul trailers, trucks, handtrucks, and towbars executed "Investment Incentive Tax Credit Lessors Election Statements," electing as lessors to pass through the investment tax credit on such equipment to U-Haul International as lessee. Petitioner and U-Haul International filed a consolidated tax return for the fiscal year ended Mar. 31, 1973, claiming the investment tax credit covered by the elections. Held: U-Haul International was the lessee of the trailers, trucks, handtrucks, and towbars. Accordingly, U-Haul International was…
1Opinion of the Court
Sterrett, Judge:
In his notice of deficiency dated November 2, 1979, respondent determined deficiencies in petitioner’s Federal income taxes for the taxable years ended March 31, 1973, and March 31, 1974, in the respective amounts of $305,499.34 and $2,484.48. After concessions by the parties, the sole issue remaining for decision is whether, pursuant to sections 38 and 48(d), I.R.C. 1954, U-Ha.ul International, a subsidiary corporation of petitioner, is entitled to claim an investment tax credit on certain fleet owners’ trailers, trucks, handtrucks, and towbars placed in the U-Haul rental…
2Cases cited6 opinions
- Kingsbury v. CommissionerUnited States Tax Court · 1976
- University Hill Foundation v. CommissionerUnited States Tax Court · 1969
- State National Bank of El Paso, Trustee for Lee Moor Children's Home v. United StatesCourt of Appeals for the Fifth Circuit · 1975
- Grandview Mines v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1960
- University Hill Foundation, Etc. v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1971
1 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Freesen v. CommissionerUnited States Tax Court · 1985
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- Weimer v. CommissionerUnited States Tax Court · 1987
- Wood v. CommissionerUnited States Tax Court · 1991
5 more not listed; retrieve them via the Exa API.