Legal Opinion
Transamerica Corp. v. United States
United States Court of Claims
Decided February 22, 1985No. Nos. 90-79T, 91-79TPublishedCited by 3 opinions
1Opinion of the Court
OPINION ON AIRCRAFT DISPOSITIONS
PHILIP R. MILLER, Judge:
The question here presented is whether plaintiff’s subsidiary, Transamerica International Airways (TIA), disposed of its beneficial interest in two large aircraft in 1968 and 1969, or in 1970 and 1972; and this in *443turn depends upon whether the 1968 agreement, pursuant to which the dispositions were made, was a conditional sales contract or a lease with options in the lessee to purchase, which were not exercised until 1970 and 1972. The resolution of these questions determines whether or not plaintiff was properly subjected to…
2Cases cited18 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Lewis v. ReynoldsSupreme Court of the United States · 1932
- Walburga Oesterreich v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1955
- Burnet v. S. & L. Building Corp.Supreme Court of the United States · 1933
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3Cited by3 opinions
- Transamerica Corp. v. United StatesUnited States Court of Claims · 1988
- Coastal Heart Med. Group, Inc. v. Comm'rUnited States Tax Court · 2015
- Kanetzke v. CommissionerUnited States Tax Court · 1991