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amount of $6,928.79 and to credit that amount to the account of
petitioner. Petitioner's and Proz' instructions were similar,
except that petitioner's account was to be charged $6,908.79,
with that amount to be credited to the account of Proz, and Proz'
account was to be charged $6,908.79, with that amount to be
credited to the account of Sha-Li.
The Telecommunications Equipment Activity
Purchase by RTS and Lease to U.S. Telephone
RTS Teleleasing Corp. (RTS) is a New York corporation
involved in equipment sales and leasing. The initials RTS in the
name "RTS Teleleasing Corporation" stand for Richard T. Santulli
(petitioner). During the years in issue, petitioner indirectly
owned 50 percent of the shares of stock of RTS. On October 1,
1982, RTS purchased certain telecommunications equipment (the
telecommunications equipment) from a corporation then known as
U.S. Telephone Communications, Inc. (U.S. Telephone). (U.S.
Telephone is now known as U.S. Sprint.) RTS purchased the
telecommunications equipment for $3,610,205. Also on October 1,
1982, RTS leased the telecommunications equipment back to U.S.
Telephone pursuant to an agreement entitled "Master Agreement of
Lease" (the U.S. Telephone lease). The term of the U.S.
Telephone lease is 60 months, commencing on October 1, 1982.
U.S. Telephone's monthly rental obligation under the U.S.
Telephone lease is $81,420.95.
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