Southeastern Mail Transport, Inc. v. Commissioner
United States Tax Court
Held: Petitioners Davis, not petitioner Southeastern Mail Transport, Inc., purchased during 1977 12 tractors; petitioner, Southeastern Mail Transport, Inc., is not entitled to investment tax credits on tractors purchased and resold and is taxable on gain from such sales; petitioners are not entitled to include in the basis of certain tractors and trailers interest on the deferred portion of the purchase price or in the gross proceeds of sale accrued interest on the deferred…
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Held: Petitioners Davis, not petitioner Southeastern Mail Transport, Inc., purchased during 1977 12 tractors; petitioner, Southeastern Mail Transport, Inc., is not entitled to investment tax credits on tractors purchased and resold and is taxable on gain from such sales; petitioners are not entitled to include in the basis of certain tractors and trailers interest on the deferred portion of the purchase price or in the gross proceeds of sale accrued interest on the deferred sale price; petitioners Davis are taxable on a $25,000 bonus.
1Opinion of the Court
SOUTHEASTERN MAIL TRANSPORT, INC., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent; TONY E. DAVIS AND PATRICIA M. DAVIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Southeastern Mail Transport, Inc. v. Commissioner
Docket Nos. 703-81, 732-81.
United States Tax Court
T.C. Memo 1987-104; 1987 Tax Ct. Memo LEXIS 100; 53 T.C.M. (CCH) 217; T.C.M. (RIA) 87104;
February 23, 1987.
Held: Petitioners Davis, not petitioner Southeastern Mail Transport, Inc., purchased during 1977 12 tractors; petitioner, Southeastern Mail Transport, Inc., is not entitled to investment tax credits on…
2Cases cited9 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Grodt & McKay Realty, Inc. v. CommissionerUnited States Tax Court · 1981
- Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
- Foster v. Comm'rUnited States Tax Court · 1983
- Coleman v. CommissionerUnited States Tax Court · 1986
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