James N. Russell and Marilyn B. Russell v. Commissioner of Internal Revenue

The taxpayer petitioners, James and Marilyn Russell, are husband and wife and reside in Northfield, Illinois. In 1983 the taxpayers entered into the business of owning and leasing compressed gas cylinders and based upon their April 1983 purchase of 1,500 new compressed gas cylinders for $212,750, they claimed an investment tax credit for that year in the amount of $21,-275 under Section 38 of the Internal Revenue Code. 1

In September and October 1982 the taxpayers leased the subsequently purchased 1,500 cylinders to two different companies for the following length of time:

This Agreement shall…