Hoisington v. Commissioner
United States Tax Court
Petitioners were partners in a general partnership, Power Leasing Associates (PLA), which they formed to purchase truck-tractors which would be used to haul freight for a freight transportation company (GTL) in which they were officers and stock-holders. The truck-tractor units were leased to employee-drivers of GTL whe were required to lease the equipment, as owner-operators, to GTL.
Read the full summary
Petitioners were partners in a general partnership, Power Leasing Associates (PLA), which they formed to purchase truck-tractors which would be used to haul freight for a freight transportation company (GTL) in which they were officers and stock-holders. The truck-tractor units were leased to employee-drivers of GTL whe were required to lease the equipment, as owner-operators, to GTL. The purpose of the plan was to convert the Teamster drivers of GTL to owner-operators.The useful life of the truck-tractor units was five years.The term of the leases from PLA to the drivers was 48 months;…
1Opinion of the Court
JOHN R. HOISINGTON and MARILYN J. HOISINGTON, ET AL, 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Hoisington v. Commissioner
Docket Nos. 24255-81 24289-81, 24290-81, 24291-81, 24292-81, 24293-81, 24294-81, 24295-81.
United States Tax Court
T.C. Memo 1984-375; 1984 Tax Ct. Memo LEXIS 299; 48 T.C.M. (CCH) 556; T.C.M. (RIA) 84375;
July 23, 1984.
Petitioners were partners in a general partnership, Power Leasing Associates (PLA), which they formed to purchase truck-tractors which would be used to haul freight for a freight transportation company (GTL) in which they were officers and…
2Cases cited4 opinions
- Ridder v. CommissionerUnited States Tax Court · 1981
- Ragnar v. Hokanson and Marilyn L. Hokanson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- Bloomberg v. CommissionerUnited States Tax Court · 1980
- Leslie Leasing Co. v. CommissionerUnited States Tax Court · 1983
3Cited by2 opinions
- Hoisington v. CommissionerCourt of Appeals for the Tenth Circuit · 1987
- John R. Hoisington v. Commissioner Of Internal RevenueCourt of Appeals for the Tenth Circuit · 1987