Holder Driv-Ur-Self, Inc. v. Commissioner
United States Tax Court
Petitioner is engaged in the automobile-leasing business. Each of the automobiles used by petitioner in its business during the period here involved had a useful life of 2 years and a salvage value of 50 percent of petitioner's cost. Held: 1. Petitioner is not entitled to use the declining-balance method of depreciation because the useful life of its vehicles is less than 3 years. 2. Petitioner is entitled to depreciate its vehicles in the year of sale below the resale price.
1Opinion of the Court
Fisher, Judge:
Respondent determined deficiencies in income tax of petitioner for the year ended September 30,1956, in the amount of $15,063.46, and for the year ended September 30, 1957, in the amount of $22,521.53.
The issues presented for our consideration are: (1) Whether petitioner is entitled to depreciate its vehicles used in its car-rental business, having a useful life of 2 years, by use of the ,150-percent declining-balance method or, alternatively, by use of the 100-percent declining-balance method; and (2) whether petitioner, in the year of sale of its vehicles, is entitled to…
2Cases cited7 opinions
- Massey Motors, Inc. v. United StatesSupreme Court of the United States · 1960
- Detroit Edison Co. v. CommissionerSupreme Court of the United States · 1943
- Manning v. Seeley Tube & Box Co.Supreme Court of the United States · 1950
- Hertz Corp. v. United StatesSupreme Court of the United States · 1960
- Shainberg v. CommissionerUnited States Tax Court · 1959
2 more not listed; retrieve them via the Exa API.
3Cited by7 opinions
- Silver Queen Motel v. CommissionerUnited States Tax Court · 1971
- Abc Rentals Of San Antonio, Inc. v. Commissioner Of Internal RevenueCourt of Appeals for the Tenth Circuit · 1998
- ABC Rentals of San Antonio, Inc. v. CommissionerCourt of Appeals for the Tenth Circuit · 1998
- Hays v. CommissionerUnited States Tax Court · 1965
- Holder Driv-Ur-Self, Inc. v. CommissionerUnited States Tax Court · 1964
2 more not listed; retrieve them via the Exa API.