Peterson v. Commissioner
United States Tax Court
Held: Because the term of the lease was not limited to the three-year period stated in the lease agreement but was of indefinite duration, it was not less than 50 percent of the useful life of the leased equipment; therefore, sec. 46(e)(3) precluded the lessor from taking any investment credit with respect to such property.
1Opinion of the Court
VAN D. PETERSON, JR., ET AL., 1 Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Peterson v. Commissioner
Docket No. 8237-80.
United States Tax Court
T.C. Memo 1982-442; 1982 Tax Ct. Memo LEXIS 310; 44 T.C.M. (CCH) 674; T.C.M. (RIA) 82442;
August 2, 1982.
Held: Because the term of the lease was not limited to the three-year period stated in the lease agreement but was of indefinite duration, it was not less than 50 percent of the useful life of the leased equipment; therefore, sec. 46(e)(3) precluded the lessor from taking any investment credit with respect to such property.
William W.…
2Cases cited9 opinions
- Buddy Schoellkopf Products, Inc. v. CommissionerUnited States Tax Court · 1975
- Ridder v. CommissionerUnited States Tax Court · 1981
- Kerr-Cochran, Inc. v. CommissionerUnited States Tax Court · 1958
- G. W. Van Keppel Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
- Highland Hills Swimming Club, Inc., a Corporation v. Earl R. Wiseman, District Director Internal RevenueCourt of Appeals for the Tenth Circuit · 1959
4 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
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- August J. Hauptli, Jr., and Barbara Hauptli v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1991
- 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