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LESLIE LEASING CO. v. COMMISSIONER

Docket No. 16498-79.

80 T.C. 411 (1983)

LESLIE LEASING COMPANY, A.K.A. LESLIE FINANCE AND LEASING COMPANY, A CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 15, 1983.

Attorney(s) appearing for the Case

Charles W. Tuckman, for the petitioner.

Robert W. Towler, for the respondent.

SHIELDS, Judge:*

Respondent determined deficiencies in petitioner's 1975 and 1976 Federal income taxes in the respective amounts of $40,575 and $64,171. After concessions by both parties,1 the remaining issues for decision are: (1) Whether petitioner's commercial, open-end "leases" are qualified motor vehicle agreements within the meaning of section 210, Tax Equity and Fiscal Responsibility Act of 1982...

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