Barry B. Bealor and Nancy L. Bealor, et al. - Page 36

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          entries.  These transactions were unwound in the same way.  None            
          of these transactions were accompanied by transfers of cash, the            
          drawing of checks, or the issuance of notes.                                
               Additionally, the termination agreements often called for              
          assignments of notes in order to carry out their provisions, but            
          often no such assignments were made.                                        
               In circumstances such as these, when the validity of                   
          financial transactions is called into serious question, reliance            
          upon bookkeeping entries will not suffice.                                  
               e.  Reasonableness of Income Projections                               
               We have examined the reasonableness of projections of income           
          expected to emanate from a transaction as a means of evaluating             
          its economic substance.  See, e.g., Rice's Toyota World, Inc. v.            
          Commissioner, 81 T.C. 184, 204-207 (1983), affd. in part, revd.             
          in part, and remanded 752 F.2d 89 (4th Cir. 1985).  Here,                   
          petitioners insist that the partnerships' contemplated gross                
          profits, in terms of 15 or 20 percent "overrides" and 10 percent            
          late fees, were reasonable and consistent with contemporary                 
          standards in the leasing industry.  Petitioners further point out           
          that some of the payments, including compensation fees and late             
          fees, were reported as taxable income by the partnerships.                  
               Petitioners’ contentions that the transactions had economic            
          substance, in the form of actual earnings that resulted in                  
          taxable income in the later years of the partnerships, are                  
          without merit.  The partners only lost money on these deals.                




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