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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