Court of Appeals for the Tenth Circuit April 25, 1991, 89-2281 (Albert E. Schumacher and Eunice A. Schumacher v. The United States of America)

ALDISERT, Circuit Judge.

In this ease of statutory construction, the issue for decision is whether the taxpayers, lessors of personal property, have shown that the rentals of their property met the requirements of Internal Revenue Code § 46(e)(3)(B), that the rentals or leases be for less than 50% of the useful life of that property, thereby entitling them to an investment tax credit.