114 T.C. No. 3
UNITED STATES TAX COURT
PAYLESS CASHWAYS, INC., AND ITS SUBSIDIARIES, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 26342-95. Filed February 16, 2000.
P equipped and furnished 5 of 11 floors of a
building it leased for its corporate headquarters. The
owner of the building was a limited partnership (TPS)
in which P had a 16-2/3-percent interest. TPS signed a
contract for the construction of the building on Apr.
4, 1985. P took possession of the leased space in
October 1986.
P claimed an investment tax credit for its taxable
year ending Nov. 29, 1986, for the cost of the
equipment and furnishings acquired and placed in
service at P’s corporate headquarters. R disallowed
the claimed credits.
The Tax Reform Act of 1986 (TRA), Pub. L. 99-514,
100 Stat. 2085, generally repealed the investment
credit for property acquired or placed in service after
Dec. 31, 1985. However, P’s claim for investment tax
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