Borchers v. Commissioner
United States Tax Court
P's claimed an investment tax credit for 1982 in respect of computer equipment purchased by P in 1982 and leased by him to a corporation wholly owned by P's. On their face the leases were for 12-month terms and contained no provision for renewal. All of the leases were in fact renewed in 1983, again for 12-month terms.
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P's claimed an investment tax credit for 1982 in respect of computer equipment purchased by P in 1982 and leased by him to a corporation wholly owned by P's. On their face the leases were for 12-month terms and contained no provision for renewal. All of the leases were in fact renewed in 1983, again for 12-month terms. Similarly, P had leased other equipment to the corporation in 1981 on 12-month leases which were renewed in 1982, some of which were again renewed in 1983. All the renewals were for 12-month periods with substantially the same provisions, except that individual leases had…
1Opinion of the Court
Richard J. Borchers and Jane E. Borchers, Petitioners v. Commissioner of Internal Revenue, Respondent
Borchers v. Commissioner
Docket No. 3576-86
United States Tax Court
95 T.C. 82; 1990 U.S. Tax Ct. LEXIS 70; 95 T.C. No. 7;
July 19, 1990, Filed
Decision will be entered for the respondent.
P's claimed an investment tax credit for 1982 in respect of computer equipment purchased by P in 1982 and leased by him to a corporation wholly owned by P's. On their face the leases were for 12-month terms and contained no provision for renewal. All of the leases were in fact renewed in 1983, again for 12-month…
2Cases cited25 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Michael L. Rockwell, and Regina Rockwell v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1975
- Raul Llorente v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1981
- Llorente v. CommissionerUnited States Tax Court · 1980
- United States v. Felix Benitez RexachCourt of Appeals for the First Circuit · 1973
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