U.S. Bancorp and Its Consolidated Subsidiaries - Page 1

                                   111 T.C. No. 10                                    

                               UNITED STATES TAX COURT                                

                  U.S. BANCORP AND ITS CONSOLIDATED SUBSIDIARIES,                     
             Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent               

               Docket No. 27342-96.1              Filed September 21, 1998.           

                    P, a bank holding company, leased a mainframe                     
               computer from ICC, a finance corporation, for a 5-year                 
               term.  Less than 1 year later, P decided that the                      
               computer was no longer adequate for its needs.  P                      
               thereupon entered into a “rollover agreement” with ICC,                
               whereby the lease was terminated upon the condition,                   
               among other things, that P commit to finance the                       

               1 On Nov. 18, 1997, the Court granted petitioner's motion to           
          consolidate this case for trial, briefing, and opinion with the             
          case at docket No. 6544-97.  The issue herein is not related to             
          the issues in docket No. 6544-97 and does not involve the tax               
          years at issue in docket No. 6544-97.  Therefore, the Court, by             
          order dated Sept. 15, 1998, denied petitioner’s motion for                  
          partial summary judgment and respondent’s cross-motion for                  
          partial summary judgment on the IBM lease issue in the case at              
          docket No. 6544-97.  The order pursuant to this opinion will be             
          issued only in docket No. 27342-96.                                         

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