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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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