Lockhart Leasing Co. v. Commissioner

54 T.C. 301, 1970 U.S. Tax Ct. LEXIS 210
CourtUnited States Tax Court
DecidedFebruary 16, 1970
DocketDocket Nos. 2445-66, 523-68
StatusPublished
Cited by1 cases

This text of 54 T.C. 301 (Lockhart Leasing Co. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lockhart Leasing Co. v. Commissioner, 54 T.C. 301, 1970 U.S. Tax Ct. LEXIS 210 (tax 1970).

Opinion

OPINION

Petitioner takes the primary position that it is entitled to the invest-lent credit provided for in section 38 2 since section 48 (d) 3 of subpart B, referred to in section 38(a), specifically provides that a lessor may elect, -with respect to any new section 38 property, to treat the lessee as having acquired such property. Petitioner states that it is clear from the provisions of section 48(d) that the lessor is entitled to the investment credit pi’ovided by section 38 unless he has elected to treat the lessee as having acquired the property.

Respondent answers this argument of petitioner’s by pointing out that section 48(d) provides for a lessor to make the election to treat the lessee as having acquired the property only “with respect to any new section 38 property.” Respondent points out that section 48(a) 4 defines section 38 property as tangible personal property with respect to which, depreciation, or amortization in lien of depreciation, is allowable. It is respondent’s position that since petitioner, in substance, operated only a financing operation, no depreciation was allowable to petitioner with respect to the property which it leased to its lessee. Respondent’s primary position is that although the form used by petitioner was that of leasing the property owned by petitioner to various lessees, the substance of the transaction engaged in by petitioner was merely a financing operation. Respondent worded his contention in his brief as follows:

the factual Issue to be decided by the Court is whether Lockhart was in the business of leasing equipment or whether in substance and in economic reality Lockhart was acting in the capacity of a financing institution and holding mere security interest in the equipment

Even though respondent in his brief states the issue to 'be whether petitioner’s operation was in substance that of a financing institution holding a mere security interest, he does, in places in effect, argue that if the substance of the transaction is not a mere financing operation, then in many instances the substance of the transaction between petitioner and its various lessees resulted in a sale by petitioner of the property to the lessee. In fact, in the notices of deficiency respondent-did not determine that petitioner was engaged in a financing operation but determined that the income reported by petitioner as rental income from leased equipment was in reality income from conditional sales of such equipment and since petitioner had not elected to report such income on the installment basis of accounting provided by section 453, it could not defer any of the income received from the conditional sales.5

Petitioner makes no objection to respondent’s contention that its operation was a mere financing operation even though his determination in the notices of deficiency was that the transactions entered into by petitioner were conditional sales, but contends that under the facts here present the transactions were in substance neither financing operations nor conditional sales, but were in substance as well as in form leases of equipment.

It might be pointed out that petitioner at the trial conceded that it was not entitled to the investment credit on any of the property which was subject to leases of less than 48 months since petitioner conceded the useful life to it as a lessor was in most instances substantially equal to the original term of the lease, and, therefore, under the provisions of section 48(a) any such property would not be section 38 property entitled to an investment credit because of the requirement in section 48(a) that section 38 property have a useful life of 4 years or more. Petitioner also conceded at the trial, with respect tc certain specific leases, that the property was not section 38 property because such property had been used by the lessee of the propertj before the property was acquired by petitioner and was used by the lessee thereafter, and therefore did not meet the definition in sectioi 48 (c) 6 of used section 38 property.

Petitioner also conceded with respect to one lease that it had passec on to the lessee the right to the investment credit in accordance witl section 48 (d). It is not clear from the record whether the investmenl credit as claimed by petitioner on its returns was computed by including the cost of any specific items which petitioner now concedes are no1 properly entitled to be included in the property subject to investmenl credit, but apparently there is no disagreement between the par tie; insofar as specific items are concerned although some adjustment tc the amounts claimed by petitioner on its returns may be necessary because of petitioner’s concessions.

We do not agree with petitioner’s contention that section 48(d) grants to a taxpayer a right to an investment credit merely because he purchases property and in form makes a lease of the property tc another. We agree with respondent that section 48(d) merely gives to í lessor the right to pass on to a lessee the investment credit with respec to property which otherwise the lessor would be entitled to consider as new section 38 property.7 We also agree with respondent that sectioi 48(a) is clear that section 38 property means tangible personal prop erty with respect to which depreciation is allowable to the taxpayei claiming the investment credit.

Our issue is, therefore, whether under the facts here present, th< property which petitioner leased to its various lessees was property with respect to which petitioner was entitled to claim depreciation If in substance as well as in form, the transactions entered into ⅛ petitioner with, its various lessees were leases, the various items of property were tangible personal property with respect to which petitioner would be entitled to depreciation. We must determine whether, as a factual matter, petitioner was in substance as well as in form the lessor of the various items of property, or whether the substance of the transaction is a financing operation by petitioner or conditional sales by petitioner of the property to the various lessees. Our attention has not been called to, nor have we found, any cases in which this precise question has been considered with respect to determining a taxpayer’s right to the investment credit with the exception of the case of Lockhart Leasing Co. v. United States, an unreported case (D. Utah 1969, 24 A.F.T.R. 2d 69-5794, 69-2 U.S.T.C. par. 9705), which involved the fiscal year 1963 of the petitioner in the instant case. In Lockhart Leasing Co. v. United States, supra, the District Court, on the basis of findings of fact and conclusions of law, but without an opinion, hold that the property which was acquired by Lockhart Leasing Co. and used by its customers pursuant to the equipment-lease agreements served as a basis for the allowance of the investment credit provided for in section 38(a).

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Related

Lockhart Leasing Co. v. Commissioner
54 T.C. 301 (U.S. Tax Court, 1970)

Cite This Page — Counsel Stack

Bluebook (online)
54 T.C. 301, 1970 U.S. Tax Ct. LEXIS 210, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lockhart-leasing-co-v-commissioner-tax-1970.