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Starr’s Estate v. Commissioner

United States Court of Appeals for the Ninth Circuit
274 F.2d 294 (1959)


Delano T. Starr (plaintiff) leased a fire sprinkler system and had it installed at his plant. Under the terms of the lease, Starr was to pay a rental fee of $1,240 annually for five years, for a total of $6,200. A sprinkler system usually sells for about $4,960. After the five-year term, Starr had the option of renewing the lease for five more years for a rental fee of $32 per year. If Starr chose not to renew the lease, the lessor had the right to remove the sprinkler system from Starr’s plant. Sprinkler systems are usually custom-made and have very little value after they are removed. It is not uncommon for lessees of sprinkler systems to keep them permanently. Starr claimed deductions for rental payments amounting to $6,200. The Commissioner (defendant) disallowed the deductions. The Tax Court upheld the disallowance, holding that the rental payments were in actuality capital expenditures.

Rule of Law


Holding and Reasoning (Chambers, J.)

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