Leslie Leasing Co. v. Commissioner
United States Tax Court
In 1975 and 1976, petitioner acquired automobiles and trucks for the use of commercial and consumer customers and claimed investment tax credit on these vehicles. Respondent disallowed the investment credit on vehicles subject to open-end leases on the ground that the transactions were conditional sales.
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In 1975 and 1976, petitioner acquired automobiles and trucks for the use of commercial and consumer customers and claimed investment tax credit on these vehicles. Respondent disallowed the investment credit on vehicles subject to open-end leases on the ground that the transactions were conditional sales. Held, petitioner's commercial leases are qualified motor vehicle agreements within the meaning of sec. 210, Tax Equity and Fiscal Responsibility Act of 1982. Held, further, petitioner is not entitled to the investment tax credit or investment credit carryovers for its consumer-use vehicles,…
1Opinion of the Court
Shields, Judge: *
Respondent determined deficiencies in petitioner’s 1975 and 1976 Federal income taxes in the respective amounts of $40,575 and $64,171. After concessions by both parties,1 the remaining issues for decision are: (1) Whether petitioner’s commercial, open-end "leases” are qualified motor vehicle agreements within the meaning of section 210, Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. 97-248, 96 Stat. 324, 477; and (2) whether petitioner is entitled to an investment credit for vehicles it acquired for use by consumers pursuant to open-end "leases.”2
FINDINGS OF FACT
So…
2Cases cited11 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- McQuiston v. CommissionerUnited States Tax Court · 1982
- Northwest Acceptance Corp. v. CommissionerUnited States Tax Court · 1972
- Northwest Acceptance Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
6 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Estate of Thomas v. CommissionerUnited States Tax Court · 1985
- Peaden v. CommissionerUnited States Tax Court · 1999
- Transamerica Corp. v. United StatesUnited States Court of Claims · 1985
- Hoisington v. CommissionerUnited States Tax Court · 1984
- Estate of Thomas v. CommissionerUnited States Tax Court · 1985
4 more not listed; retrieve them via the Exa API.