ON DEFENDANT'S MOTION FOR SUMMARY JUDGMENT AND PLAINTIFF'S CROSS-MOTION FOR SUMMARY JUDGMENT
BENNETT, Judge:
This is a case of first impression under a now expired provision of the Tax Reform Act of 1969. The issue is whether plaintiff may, pursuant to I.R.C. § 184, amortize, over a 5-year period, certain railroad freight cars leased to three companies which are not railroads. The case is before the court on the parties' cross-motions for summary judgment...
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