Laurence M. And Phyllis W. Carlson v. Commissioner of Internal Revenue

EUGENE A. WRIGHT, Circuit Judge:

The issue is whether the Tax Court held correctly that taxpayer did not manufacture or produce the apple bins he leased to a fruit company, and that he was not entitled to an investment tax credit for the bins. Taxpayer contends that he exercised sufficient control over the bins’ assembly to be considered to have manufactured them, and that he is entitled to the tax credit because he leased the bins for valid business reasons. We affirm.

FACTS

Though actively involved in the apple industry, Carlson was primarily engaged in the practice of law during the years in…