Apex Corp. v. Commissioner
United States Tax Court
Petitioner purchased business, medical, and dental equipment, leased it to outside parties, thereupon sold all of its rental and lease rights to Murdock Acceptance Corp. (which had wanted to enter the business of acquiring and renting such equipment but was restricted from doing so by an outstanding debenture), and thereafter sold the particular equipment subject to the lease to Equipment, Inc., a newly organized corporation.
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Petitioner purchased business, medical, and dental equipment, leased it to outside parties, thereupon sold all of its rental and lease rights to Murdock Acceptance Corp. (which had wanted to enter the business of acquiring and renting such equipment but was restricted from doing so by an outstanding debenture), and thereafter sold the particular equipment subject to the lease to Equipment, Inc., a newly organized corporation. Murdock was president of the petitioner, Murdock Acceptance Corp., and Equipment, Inc., each of which had interrelated stockholders none of whom had a controlling…
1Opinion of the Court
TietjeNS, Judge:
The Commissioner determined deficiencies in the petitioner’s income tax as follows:
Fiscal year ended March 31— Deficiencies
1960_ $4,728. 86
1961_ 100,450.46
1962_ 32, 925.14
The two questions presented are (1) whether the petitioner could make an apportionment of its cost basis of office and business equipment between leases of the equipment, which leases it sold, and the reversionary interests which it also separately sold, in computing the gains realized by it on these separate sales of leases and reversionary interests, and (2) whether the petitioner is entitled to use its…
2Cases cited3 opinions
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Columbian Rope Co. v. CommissionerUnited States Tax Court · 1964
- Wisconsin Electric Power Co. v. CommissionerUnited States Tax Court · 1952
3Cited by4 opinions
- Principal Life Insurance Company and Subsidiaries v. United StatesUnited States Court of Federal Claims · 2014
- Apex Corp. v. CommissionerUnited States Tax Court · 1964
- Pechiney Ugine Kuhlmann Corp. v. CommissionerUnited States Tax Court · 1986
- Transport Mfg. & Equipment Co. v. CommissionerUnited States Tax Court · 1968