Sauey v. Commissioner
United States Tax Court
Petitioner, a noncorporate taxpayer, leased an airplane to a related corporation in 1976. In 1979, petitioner and the corporation entered into a second lease agreement which provided that petitioner would continue leasing the airplane to the corporation for a term of 3 years. In 1981, petitioner and the corporation terminated the 1979 lease, and petitioner traded in the airplane and purchased a new one having a useful life of 6 years.
Read the full summary
Petitioner, a noncorporate taxpayer, leased an airplane to a related corporation in 1976. In 1979, petitioner and the corporation entered into a second lease agreement which provided that petitioner would continue leasing the airplane to the corporation for a term of 3 years. In 1981, petitioner and the corporation terminated the 1979 lease, and petitioner traded in the airplane and purchased a new one having a useful life of 6 years. In September of 1981, petitioner and the corporation entered into a written lease agreement that did not contain an option to renew and provided that petitioner…
1Opinion of the Court
OPINION
STERRETT, Chief Judge:*
By notice of deficiency dated December 18, 1985, respondent determined a deficiency in petitioners’ Federal income tax for the calendar year 1981 in the amount of $8,635. Due to concessions by both parties, the only issue presented in this case is whether petitioners are entitled to an investment credit under section 381 with respect to an airplane that petitioner Norman O. Sauey, Jr., purchased and leased to a related corporation in 1981.
The parties submitted this case fully stipulated pursuant to Rule 122. The stipulation of facts and exhibits attached thereto…
2Cases cited3 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Ridder v. CommissionerUnited States Tax Court · 1981
- Donald G. McNamara and Valerie J. McNamara and Robert F. Christiansen and Lucille L. Christiansen v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987
3Cited by10 opinions
- Borchers v. CommissionerUnited States Tax Court · 1990
- August J. Hauptli, Jr., and Barbara Hauptli v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1991
- Borchers v. CommissionerUnited States Tax Court · 1988
- Borchers v. CommissionerUnited States Tax Court · 1990
- Borchers v. CommissionerUnited States Tax Court · 1990
5 more not listed; retrieve them via the Exa API.