- 123 - 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.Page: Previous 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 Next
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