McCrary v. Commissioner
United States Tax Court
Ps entered into a purported "lease" of a master recording produced by American Educational Leasing. Shortly prior to trial, they conceded that they were not entitled to the investment tax credit claimed on their tax returns because the agreement was not a lease. They continued to claim deductions for lease payments and other expenses, however. Held, Ps were not entitled to the deductions claimed.
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Ps entered into a purported "lease" of a master recording produced by American Educational Leasing. Shortly prior to trial, they conceded that they were not entitled to the investment tax credit claimed on their tax returns because the agreement was not a lease. They continued to claim deductions for lease payments and other expenses, however. Held, Ps were not entitled to the deductions claimed. Held, further, no part of the underpayment of Ps' taxes was attributable to a valuation overstatement, and they are not liable for additions to tax under sec. 6659, I.R.C. 1954. Todd v. Commissioner,…
1Opinion of the Court
Ronald W. McCrary and Diane E. McCrary, Petitioners v. Commissioner of Internal Revenue, Respondent
McCrary v. Commissioner
Docket No. 2979-86
United States Tax Court
92 T.C. 827; 1989 U.S. Tax Ct. LEXIS 55; 92 T.C. No. 50;
April 17, 1989; As corrected April 26, 1989 April 17, 1989, Filed
Decision will be entered under Rule 155.
Ps entered into a purported "lease" of a master recording produced by American Educational Leasing. Shortly prior to trial, they conceded that they were not entitled to the investment tax credit claimed on their tax returns because the agreement was not a lease. They…
Also in this document: Dissent.
2Cases cited39 opinions
- Richards v. United StatesSupreme Court of the United States · 1962
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Pallottini v. CommissionerUnited States Tax Court · 1988
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