- 25 -
transaction became unprofitable. Id. at 1317. The Court of
Appeals affirmed the holding of this Court that the taxpayer was
not at risk under section 465(b)(4). Id. at 1319. Likewise, in
Levien v. Commissioner, supra at 127-128, this Court found that
taxpayers involved in a similar computer leasing structure were
not at risk due primarily to the existence of matching, circular
payments, guarantees, and the nonrecourse nature of the
underlying debt. Accord Thornock v. Commissioner, supra.
C. Instant Cases
In the instant cases, sufficient factors are present that we
must find that there was no realistic possibility that petitioner
would suffer an economic loss on account of the installment notes
if the underlying activities became unprofitable.
1. Matching
In the computer equipment activity, Sha-Li was required to
make monthly lease payments to petitioner of $6,928.79,
petitioner was required to make monthly installment note payments
to Proz of $6,908.79, and Proz was required to make monthly
installment note payments to Sha-Li of $6,908.79. All payment
obligations were for the same term. In the telecommunications
equipment activity, all payment obligations--from RTS to
petitioner as rent, from petitioner to Proz on the Proz
telecommunications installment note, and from Proz to RTS on the
petitioner telecommunications installment note--were identical
both in amount and in term. In both activities, petitioner's
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