Egizii v. Commissioner
United States Tax Court
Petitioners sought investment credits for portions of a warehouse they leased to their controlled corporation. Held, property required to have been manufactured or produced by lessors to qualify them as noncorporate lessors eligible for the credit is sec. 38, I.R.C. 1954, property subject to the lease, not entire property subject to the lease. Held, further, petitioners did not manufacture or produce the sec. 38 property subject to the lease.
1Opinion of the Court
OPINION
Parr, Judge:*
Respondent determined a deficiency in petitioners’ Federal income tax for the calendar year 1978 in the amount of $27,757.60. The sole issue for decision is whether John E. Egizii (petitioner) or his wife, Helen Egizii, (collectively petitioners) manufactured or produced certain personal property so as to allow them to claim an investment credit under section 46(e)(3)(A),1 governing noncorporate lessors.
FINDINGS OF FACT
This case was submitted for decision without trial pursuant to Rule 122. All of the facts have been stipulated and are so found. The stipulation of facts,…
2Cases cited6 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Ridder v. CommissionerUnited States Tax Court · 1981
- Lykes Bros. Steamship v. United StatesUnited States Court of Claims · 1975
- Laurence M. And Phyllis W. Carlson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1983
- Anesthesia Service Medical Group, Inc. v. CommissionerUnited States Tax Court · 1985
1 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Faulkner v. CommissionerUnited States Tax Court · 1987
- Wood v. CommissionerUnited States Tax Court · 1991
- Egizii v. CommissionerUnited States Tax Court · 1986
- Faulkner v. CommissionerUnited States Tax Court · 1987
- Hannaman v. CommissionerUnited States Tax Court · 1991
1 more not listed; retrieve them via the Exa API.