Union Carbide Foreign Sales Corp. v. Commissioner
United States Tax Court
P leased an asset, and the terms of the lease became onerous or burdensome. Under lease agreements, P was entitled to either terminate the lease or purchase the leased asset by the payment of a certain sum. P chose to acquire the leased asset and, relying on Cleveland Allerton Hotel, Inc. v. Commissioner, 166 F.2d 805 (6th Cir. 1948), revg. a Memorandum Opinion of this Court dated May 7, 1947, seeks to bifurcate and allocate the asset acquisition cost into two portions.
Read the full summary
P leased an asset, and the terms of the lease became onerous or burdensome. Under lease agreements, P was entitled to either terminate the lease or purchase the leased asset by the payment of a certain sum. P chose to acquire the leased asset and, relying on Cleveland Allerton Hotel, Inc. v. Commissioner, 166 F.2d 805 (6th Cir. 1948), revg. a Memorandum Opinion of this Court dated May 7, 1947, seeks to bifurcate and allocate the asset acquisition cost into two portions. P asserts one portion should represent the value of the leased asset without considering the value of the existing lease. P…
1Opinion of the Court
UNION CARBIDE FOREIGN SALES CORPORATION, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Union Carbide Foreign Sales Corp. v. Commissioner
No. 14641-97; No. 14642-97; No. 14643-97; No. 1119-99
United States Tax Court
115 T.C. 423; 2000 U.S. Tax Ct. LEXIS 80; 115 T.C. No. 32;
November 8, 2000, Filed
An appropriate order will be issued.
P leased an asset, and the terms of the lease became
onerous or burdensome. Under lease agreements, P was entitled to
either terminate the lease or purchase the leased asset by the
payment of a certain sum. P chose to acquire the leased asset
and,…
2Cases cited12 opinions
- Consumer Product Safety Commission v. GTE Sylvania, Inc.Supreme Court of the United States · 1980
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
- Jones v. Liberty Glass Co.Supreme Court of the United States · 1948
7 more not listed; retrieve them via the Exa API.