Northwest Acceptance Corp. v. Commissioner
United States Tax Court
Petitioner, a sales finance company, purchased contracts from heavy-equipment dealers under which the equipment was placed in the possession of the user. Some of the contracts were identified as security agreements, while others were designated as leases.
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Petitioner, a sales finance company, purchased contracts from heavy-equipment dealers under which the equipment was placed in the possession of the user. Some of the contracts were identified as security agreements, while others were designated as leases. Under the terms of the "leases" the users were called upon to pay rental over the term of the contract, and had an option to purchase the equipment at a percentage of its cost to petitioner at the termination of the contract. Many of the contracts contained a guaranty by the dealer or a third party of the user's performance of the lease and…
1Opinion of the Court
Drennen, Judge:
Respondent determined deficiencies in petitioner’s income taxes in the amounts of $38,592 and $244,931 for the taxable years ended April 30, 1966, and April 30,1967, respectively. The sole issue for our decision is whether petitioner is entitled to depreciation deductions and investment credits for equipment placed in the possession of its customers under the terms of certain contracts which are purported to be leases.
FINDINGS OF FACT
The stipulated facts, together with the exhibits attached thereto, are incorporated herein by this reference.
Northwest Acceptance Corp.…
2Cases cited14 opinions
- Haggard v. CommissionerUnited States Tax Court · 1955
- D. M. Haggard and Nila Haggard v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1956
- Mills v. CommissionerUnited States Tax Court · 1948
- Bowen v. CommissionerUnited States Tax Court · 1949
- Breece Veneer and Panel Company v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1956
9 more not listed; retrieve them via the Exa API.
3Cited by42 opinions
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Coleman v. CommissionerUnited States Tax Court · 1986
- Ross Glove Co. v. CommissionerUnited States Tax Court · 1973
- Northwest Acceptance Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1974
- Kansas City S. R. Co. v. CommissionerUnited States Tax Court · 1981
37 more not listed; retrieve them via the Exa API.