Bussing v. Commissioner
United States Tax Court
AG acquired computer equipment in a sale-leaseback transaction. The equipment was in place and in operation in Zurich, Switzerland. AG purported to convey its interest in the equipment to Sutton. Sutton purported to convey its interest in the equipment to P and four other investors.
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AG acquired computer equipment in a sale-leaseback transaction. The equipment was in place and in operation in Zurich, Switzerland. AG purported to convey its interest in the equipment to Sutton. Sutton purported to convey its interest in the equipment to P and four other investors. P leased his interest in the equipment to AG under a net-net-net lease, under which AG shared in subrent; P retained AG as his agent to market his interest in the equipment, in exchange for which AG shared in residual value. P's obligations pursuant to his purchase agreement with Sutton were financed by the rent…
1Opinion of the Court
WILLIAMS, Judge:
The Commissioner determined deficiencies in petitioners’ Federal income tax and additions to tax as follows:
Taxable year Deficiency Sec. 6653(a)1 addition to tax
$19,933 1979 $997
1980 17,316 866
1981 9,848 492
The issue this Court must decide is whether petitioners are entitled to deductions for depreciation and interest claimed with respect to petitioner Irvin Bussing’s interest in certain computer equipment.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. Irvin Bussing (hereinafter, Bussing) and Elizabeth Bussing were husband and wife who resided at San…
2Cases cited17 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. CulbertsonSupreme Court of the United States · 1949
- Commissioner v. TowerSupreme Court of the United States · 1946
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
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3Cited by35 opinions
- Larsen v. CommissionerUnited States Tax Court · 1987
- Friendship Dairies, Inc. v. CommissionerUnited States Tax Court · 1988
- Estate of Maddox v. CommissionerUnited States Tax Court · 1989
- Bussing v. CommissionerUnited States Tax Court · 1987
- Reinberg v. CommissionerUnited States Tax Court · 1988
30 more not listed; retrieve them via the Exa API.