Electric & Neon, Inc. v. Commissioner
United States Tax Court
1. The corporate petitioner constructed custom-made signs which it leased to customers. Lease durations varied from 1 to 10 years, the most common duration being 5 years. Leases were sometimes not renewed; when renewed, the rental rate was often substantially reduced. The signs were generally of no use to anyone but the original lessees.
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1. The corporate petitioner constructed custom-made signs which it leased to customers. Lease durations varied from 1 to 10 years, the most common duration being 5 years. Leases were sometimes not renewed; when renewed, the rental rate was often substantially reduced. The signs were generally of no use to anyone but the original lessees. Held: The costs of constructing the signs must be treated as capital expenditures, depreciable over the term of the original lease in each case. An adjustment under sec. 481, I.R.C. 1954, must be made with respect to the transitional year. 2. The individual…
1Opinion of the Court
Electric & Neon, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent; Luis and Alicia Jimenez, Petitioners v. Commissioner of Internal Revenue, Respondent
Electric & Neon, Inc. v. Commissioner
Docket Nos. 1058-66, 3259-70, 1059-66, 3220-70
United States Tax Court
56 T.C. 1324; 1971 U.S. Tax Ct. LEXIS 56;
September 21, 1971, Filed
Decisions will be entered under Rule 50.
1. The corporate petitioner constructed custom-made signs which it leased to customers. Lease durations varied from 1 to 10 years, the most common duration being 5 years. Leases were sometimes not renewed; when renewed,…
2Cases cited45 opinions
- Beaver v. CommissionerUnited States Tax Court · 1970
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Electric & Neon, Inc. v. CommissionerUnited States Tax Court · 1971
- Challenge Mfg. Co. v. CommissionerUnited States Tax Court · 1962
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
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