Cooper v. Commissioner
United States Tax Court
Ps purchased solar water heating systems, on a leveraged basis, from Bliss; thereafter, pursuant to a prearranged agreement, Ps leased the systems to Coordinated for a term of 7 years. Coordinated subleased the systems to homeowners. Included in Ps' lease agreement with Coordinated was an option whereby Ps could require Coordinated to purchase the systems upon the expiration of the lease for an amount not less than the balance still owed on the notes to Bliss.
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Ps purchased solar water heating systems, on a leveraged basis, from Bliss; thereafter, pursuant to a prearranged agreement, Ps leased the systems to Coordinated for a term of 7 years. Coordinated subleased the systems to homeowners. Included in Ps' lease agreement with Coordinated was an option whereby Ps could require Coordinated to purchase the systems upon the expiration of the lease for an amount not less than the balance still owed on the notes to Bliss. Bliss guaranteed Coordinated's obligations under the leases. Held: Ps entered into the transactions with a bona fide objective to make…
1Opinion of the Court
JACOBS, Judge:
Each of these consolidated cases involves the disallowance of deductions and tax credits claimed by petitioners 2 in connection with their purchases of solar water heating systems from A.T. Bliss & Co., Inc. (A.T. Bliss). Appendix A lists petitioners by name, the tax years involved, the deficiencies and additions to tax for each year, the place of residence for each individual petitioner, and the principal place of business for each corporate petitioner at the time their respective petitions were filed. Other issues unrelated to the aforementioned issue common to all petitioners…
2Cases cited56 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Gregory v. HelveringSupreme Court of the United States · 1935
- Spies v. United StatesSupreme Court of the United States · 1943
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
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3Cited by25 opinions
- Zola v. GordonDistrict Court, S.D. New York · 1988
- Sealy Power, Ltd. v. CommissionerCourt of Appeals for the Fifth Circuit · 1995
- McManus v. CommissionerUnited States Tax Court · 1987
- MANNING v. COMMISSIONERUnited States Tax Court · 1993
- United States v. Rapower-3, LLCDistrict Court, D. Utah · 2018
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