Legal Opinion

Bowen v. Commissioner

United States Tax Court

Decided March 25, 1949No. Docket No. 12319Published

A partnership furnished equipment to the Government during 1941 for use at construction work to which the Government took title during 1942. The value of each item of equipment was agreed upon. Monthly payments called rent were made. The monthly payments were treated as equity of the Government under the agreements. Title was to pass to the Government when the monthly payments equaled value plus charges for interest at the rate of 1 per cent of value per month plus freight.

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A partnership furnished equipment to the Government during 1941 for use at construction work to which the Government took title during 1942. The value of each item of equipment was agreed upon. Monthly payments called rent were made. The monthly payments were treated as equity of the Government under the agreements. Title was to pass to the Government when the monthly payments equaled value plus charges for interest at the rate of 1 per cent of value per month plus freight. The Government could take title upon completion of work by a further payment which, added to monthly payments, would…

1Opinion of the Court

Truman Bowen, Petitioner, v. Commissioner of Internal Revenue, Respondent

Bowen v. Commissioner

Docket No. 12319

United States Tax Court

12 T.C. 446; 1949 U.S. Tax Ct. LEXIS 241;

March 25, 1949, Promulgated

Decision will be entered under Rule 50.

A partnership furnished equipment to the Government during 1941 for use at construction work to which the Government took title during 1942. The value of each item of equipment was agreed upon. Monthly payments called rent were made. The monthly payments were treated as equity of the Government under the agreements. Title was to pass to the Government when…

Also in this document: Dissent · Murdock; Dissent · Johnson.

2Cases cited10 opinions

  1. Mills v. CommissionerUnited States Tax Court · 1948
  2. Bowen v. CommissionerUnited States Tax Court · 1949
  3. Gilken Corp. v. CommissionerUnited States Tax Court · 1948
  4. Union Stock-Yards & Transit Co. v. Western Land & Cattle Co.Court of Appeals for the Seventh Circuit · 1893
  5. Central Union Gas Co. v. . BrowningNew York Court of Appeals · 1913

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