Norfolk Southern Corp. v. Commissioner
United States Tax Court
Ps claimed investment tax credit (ITC) on their 1981 consolidated Federal income tax return and accelerated depreciation deductions on their 1981 through 1985 consolidated Federal income tax returns.
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Ps claimed investment tax credit (ITC) on their 1981 consolidated Federal income tax return and accelerated depreciation deductions on their 1981 through 1985 consolidated Federal income tax returns. The ITC and depreciation related to certain intermodal cargo containers (containers) included under a safe harbor lease agreement entered into with F on Nov. 13, 1981, pursuant to sec. 168(f)(8), I.R.C.Sec. 48(a)(2)(A), I.R.C., generally excludes property used predominantly outside the United States from "eligible section 38 property". Sec. 48(a)(2)(B)(v), I.R.C., excepts from sec. 48(a)(2)(A),…
1Opinion of the Court
Parr, Judge:
Respondent determined the following deficiencies in petitioners’ Federal corporate income taxes, net of offsets for credits or refunds of overassessments of taxes to which respondent agrees petitioners are entitled:1
Net Year deficiency
1981. $8,274,876
1982 . 5,859,265
1983 . 6,319,433
1984 . 736,022
1985 . 6,788,350
Total . 27,977,946
These cases were consolidated for trial, briefing, and opinion. The ultimate issue for decision is whether petitioners may claim investment tax credit (itc) and accelerated depreciation deductions for certain intermodal cargo containers2 (containers)…
2Cases cited105 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- New Colonial Ice Co. v. HelveringSupreme Court of the United States · 1934
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- Richards v. United StatesSupreme Court of the United States · 1962
- Dewsnup v. TimmSupreme Court of the United States · 1992
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3Cited by79 opinions
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Redlark v. Comm'rUnited States Tax Court · 1996
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1996
- Berry Petroleum Co. v. CommissionerUnited States Tax Court · 1995
74 more not listed; retrieve them via the Exa API.