Cooper Tire & Rubber Co. Employees' Retirement Fund v. Commissioner

This case comes before us on petition to review the decision of the Tax Court of the United States. The facts were stipulated in that court and only a legal question was presented.

*21Taxpayer was an exempt employees’ retirement trust created by Cooper Tire & Rubber Company. The trust purchased twenty tire manufacturing machines and one press from the manufacturer thereof for $344,800.00. The trust borrowed $200,000.00 of the purchase price from a bank and executed a chattel mortgage on the machines to secure the loan. The trust then leased the machines to the tire company for 10 years, with…