Legal Opinion

Peterson v. Commissioner

United States Tax Court

Decided August 2, 1982No. Docket No. 8237-80UnpublishedCited by 5 opinions

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

  1. Buddy Schoellkopf Products, Inc. v. CommissionerUnited States Tax Court · 1975
  2. Ridder v. CommissionerUnited States Tax Court · 1981
  3. Kerr-Cochran, Inc. v. CommissionerUnited States Tax Court · 1958
  4. G. W. Van Keppel Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
  5. 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

  1. Donald G. McNamara and Valerie J. McNamara and Robert F. Christiansen and Lucille L. Christiansen v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987
  2. Eugene R. Connor and Mary P. Connor v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
  3. August J. Hauptli, Jr., and Barbara Hauptli v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1991
  4. Hoisington v. CommissionerCourt of Appeals for the Tenth Circuit · 1987
  5. John R. Hoisington v. Commissioner Of Internal RevenueCourt of Appeals for the Tenth Circuit · 1987

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