Legal Opinion
Hoisington v. Commissioner
Court of Appeals for the Tenth Circuit
Decided November 25, 1987No. 85-1229PublishedCited by 6 opinions
1Opinion of the Court
STEPHEN H. ANDERSON, Circuit Judge.
During the years in issue section 46(e)(3)(B) of the Internal Revenue Code of 1954 (“Code”)1 permitted an investment credit to noncorporate lessors only if, among other requirements, “the term of the lease (taking into account options to renew) is less than 50 percent of the useful life of the property.” A partnership formed by the taxpayers involved in this case purchased and leased twenty-two trucks to owner-operators under leases having fixed terms, usually four years, well in excess of fifty percent of the useful lives of the trucks. Cancellation of the…
2Cases cited16 opinions
- Ridder v. CommissionerUnited States Tax Court · 1981
- Ragnar v. Hokanson and Marilyn L. Hokanson v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1984
- G. W. Van Keppel Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961
- Highland Hills Swimming Club, Inc., a Corporation v. Earl R. Wiseman, District Director Internal RevenueCourt of Appeals for the Tenth Circuit · 1959
- Donald G. McNamara and Valerie J. McNamara and Robert F. Christiansen and Lucille L. Christiansen v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1987
11 more not listed; retrieve them via the Exa API.
3Cited by6 opinions
- Eugene R. Connor and Mary P. Connor v. Commissioner of Internal RevenueCourt of Appeals for the First Circuit · 1988
- William F. Owen, Jr. Gretchen K. Owen v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1989
- John R. Hoisington v. Commissioner Of Internal RevenueCourt of Appeals for the Tenth Circuit · 1987
- Mullins v. CommissionerUnited States Tax Court · 1989
- Phillips v. CommissionerUnited States Tax Court · 1992
1 more not listed; retrieve them via the Exa API.