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.Held, Ps are not entitled to claim depreciation under sec. 168(f)(2) for any containers which do not meet the definition of "qualified leased property" under sec. 168(f)(8)(D). Norfolk S. Corp. v.…
1Opinion of the Court
SUPPLEMENTAL OPINION
Parr, Judge:
The Court’s opinion in these cases, 104 T.C. 13 (1995), was issued on January 11, 1995 (prior opinion). Thereafter, on February 13, 1995, pursuant to Rule 161,1 respondent filed a motion for reconsideration of opinion. The Court directed petitioners to file a response to respondent’s motion. On March 6, 1995, petitioners filed their objection to respondent’s motion for reconsideration.
Background,
During 1981, petitioners entered into an agreement with Flexi-Van Leasing, Inc. (Flexi-Van), a large lessor of inter-modal cargo containers, intended to qualify as a…
2Cases cited4 opinions
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Greiner v. LewellynSupreme Court of the United States · 1922
- Armstrong World Industries, Inc., and Affiliated Companies v. Commissioner of Internal RevenueCourt of Appeals for the Third Circuit · 1992
- Greene v. CommissionerUnited States Tax Court · 1987
3Cited by37 opinions
- Elec. Arts, Inc. v. Comm'rUnited States Tax Court · 2002
- Redlark v. Comm'rUnited States Tax Court · 1996
- Hospital Corp. of Am. v. CommissionerUnited States Tax Court · 1996
- Nelson v. CommissionerUnited States Tax Court · 1998
- Medchem (P.R.), Inc. v. CommissionerCourt of Appeals for the First Circuit · 2002
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