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MOTORLEASE CORPORATION v. UNITED STATES

Civ. No. 9128.

215 F.Supp. 356 (1963)

The MOTORLEASE CORPORATION v. UNITED STATES of America.

United States District Court D. Connecticut.

As Corrected March 26, 1963.

Attorney(s) appearing for the Case

Norris L. O'Neill, Hartford, Conn., for plaintiff.

Louis F. Oberdorfer, Asst. Atty. Gen., David A. Wilson, Jr., Lyle M. Turner, Herman Wilson, Department of Justice, Washington, D. C., Robert C. Zampano, U. S. Atty., New Haven, Conn., Irving H. Perlmutter, Asst. U. S. Atty., Hartford, Conn., on the brief, for defendant.

Ellis Lyons, Washington, D. C., for American Automotive Leasing Ass'n, amicus curiæ.

BLUMENFELD, District Judge.

RULING ON CROSS MOTIONS FOR SUMMARY JUDGMENT

The plaintiff, Motorlease Corporation, seeks to recover payments of income taxes plus interest made in response to deficiency assessments for the fiscal years ended September 30, 1957, 1958, 1959 and 1960. As its name suggests, the plaintiff is in the business of leasing its automobiles to others. For each year, the taxpayer reported gains which arose from the sale of certain of those...

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