United States Federal Circuit

In a dispute involving the federal income tax consequences of sale-in, lease-out (SILO) transactions, decision by trial court denying plaintiff claimed deductions for tax year 2002 stemming from its participation in 26 SILO transactions with tax-exempt entities is affirmed because plaintiff was not entitled to deductions for depreciation of assets and associated interests and expenses, as it failed to show that it owned SILO equipments.

Appellate Information

• Decided 04/15/2011
• Published 04/15/2011

Judges

• BRYSON

Court

• United States Federal Circuit

Counsel