Rice's Toyota World, Inc. v. Commissioner
United States Tax Court
Petitioner entered into a purchase-and-leaseback arrangement with a computer equipment leasing corporation. Pursuant to this agreement, petitioner purchased a 6-year-old computer for $ 1,455,227. The purchase price was paid in the form of a 4-year promissory note in the amount of $ 250,000 and the balance in two nonrecourse notes payable over an 8-year period. Simultaneously, petitioner leased the equipment back to the equipment leasing corporation for 8 years.
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Petitioner entered into a purchase-and-leaseback arrangement with a computer equipment leasing corporation. Pursuant to this agreement, petitioner purchased a 6-year-old computer for $ 1,455,227. The purchase price was paid in the form of a 4-year promissory note in the amount of $ 250,000 and the balance in two nonrecourse notes payable over an 8-year period. Simultaneously, petitioner leased the equipment back to the equipment leasing corporation for 8 years. The equipment leasing corporation's monthly rental payments to petitioner purported to amortize petitioner's nonrecourse note…
1Opinion of the Court
Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.), Petitioner v. Commissioner of Internal Revenue, Respondent
Rice's Toyota World, Inc. v. Commissioner
Docket No. 16079-80
United States Tax Court
81 T.C. 184; 1983 U.S. Tax Ct. LEXIS 51; 81 T.C. No. 16;
August 29, 1983, Filed
Decision will be entered under Rule 155.
Petitioner entered into a purchase-and-leaseback arrangement with a computer equipment leasing corporation. Pursuant to this agreement, petitioner purchased a 6-year-old computer for $ 1,455,227. The purchase price was paid in the form of a 4-year promissory note in the amount of…
2Cases cited27 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Crane v. CommissionerSupreme Court of the United States · 1947
- Helvering v. F. & R. Lazarus & Co.Supreme Court of the United States · 1939
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