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Petitioners Richard and Virginia Santulli are husband and wife.
They made joint returns of Federal income tax for the calendar
years in issue. Petitioners resided in New York City at the time
they filed the petitions herein. Hereafter, all references to
petitioner shall refer to petitioner Richard Santulli.
Our remaining findings of fact are concerned with two
equipment leasing transactions entered into by petitioner. One
of those transactions involved computer equipment, and the other
involved telecommunications equipment. The parties have
characterized those transactions as the "computer equipment
activity" and the "telecommunications equipment activity",
respectively. We will adopt those characterizations.
The Computer Equipment Activity
Purchase by Sha-Li and Lease to BNY
Sha-Li Leasing Associates, Inc. (Sha-Li), is a New Jersey
corporation involved in equipment sales and leasing. During the
years in issue, petitioner was a director of Sha-Li. Sometime
prior to January 1979, Sha-Li purchased certain computer
equipment (the computer equipment), which it leased to the Bank
of New York (BNY), pursuant to eight separate leases (the BNY
leases). The dates of, terms of, and monthly rental obligations
under the BNY leases are as follows:
Date of Lease Term Monthly Rental
12/19/78 48 mos. $1,177
12/19/78 48 mos. 1,188
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