Greenville Steel Car Co. v. United States

The issue is whether plaintiff may, pursuant to I.R.C. § 184, amortize, *402over a 5-year period, certain railroad freight cars leased to three companies which are not railroads. The case is before the court on the parties’ cross-motions for summary judgment. We conclude that the cars leased by plaintiff to the nonrailroad companies were not "qualified railroad rolling stock” within the meaning of I.R.C. § 184(d)(1)(A). Therefore, we grant defendant’s motion for summary judgment.

Plaintiff, Greenville Steel Car Company, manufactures and rebuilds all types of railroad cars for sale or lease to…