Operating lease ownership supports depreciation despite lessee registration, while undecided maintenance-charge grounds require fresh determination.
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....Depreciation on vehicles under operating leases is discussed in relation to ownership where registration certificates stand in customers' names. Master Lease Agreements may establish the lessor's ownership and customers' limited right of use; registration and lessee use do not, by themselves, displace depreciation eligibility. The text also addresses an undecided ground concerning deferred maintenance charges, noting that where a specifically raised ground has not been determined, it requires limited fresh consideration. It describes depreciation questions as not raising a substantial question of law and the maintenance-charge issue as remanded for determination.....
TaxTMI