Seligman v. Commissioner
United States Tax Court
Petitioners purchased computer equipment packages for lease. The leases required petitioners to pay $ 225 each month for the first 12 months for lease administration services to be performed over the entire 41 months of the leases. Held: Petitioners cannot deduct the payments to M pursuant to sec. 162, I.R.C. 1954. Petitioners must capitalize these expenditures and amortize their cost over the entire lives of the leases.
Read the full summary
Petitioners purchased computer equipment packages for lease. The leases required petitioners to pay $ 225 each month for the first 12 months for lease administration services to be performed over the entire 41 months of the leases. Held: Petitioners cannot deduct the payments to M pursuant to sec. 162, I.R.C. 1954. Petitioners must capitalize these expenditures and amortize their cost over the entire lives of the leases. Commissioner v. Lincoln Savings & Loan Association, 403 U.S. 345 (1971), followed.
1Opinion of the Court
Goffe, Judge:
The Commissioner determined deficiencies in the petitioners’ Federal income taxes for the taxable years as follows:
Docket Nos. 1978 1979
16854-82 $21,583.14 $14,130.78
17467-82 11,842.85
After concessions by the parties, the issue for decision is whether petitioners2 are entitled to deduct under section 1623 certain administrative leasing expenses paid in connection with their computer leasing activities.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts and accompanying exhibits are so found and incorporated herein by reference.
Petitioners Milton…
2Cases cited24 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. Lincoln Savings & Loan Ass'nSupreme Court of the United States · 1971
- Estate of Horvath v. CommissionerUnited States Tax Court · 1973
- Boagni v. CommissionerUnited States Tax Court · 1973
- United States v. Mississippi Chemical Corp.Supreme Court of the United States · 1972
19 more not listed; retrieve them via the Exa API.
3Cited by101 opinions
- Neely v. CommissionerUnited States Tax Court · 1985
- Antonides v. CommissionerUnited States Tax Court · 1988
- Waddell v. CommissionerUnited States Tax Court · 1986
- Levy v. CommissionerUnited States Tax Court · 1988
- Leahy v. CommissionerUnited States Tax Court · 1986
96 more not listed; retrieve them via the Exa API.