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We next look to see whether there were other elements of the
transactions which protected decedent against loss. We note
initially that respondent's argument that the financial solvency
and good credit rating of the various parties to the transaction
made decedent less at risk was specifically rejected in Gefen v.
Commissioner, 87 T.C. 1471 (1986).
Respondent next emphasizes the circular nature of the
payments--the partnership's debt payments were exactly offset by
the rental payments it received from Hambrose. This circularity
is set forth in the stipulation and the stipulated documents as
well as the POM. As we have previously held, circular payments
do not per se constitute "other similar arrangements" for
purposes of section 465(b)(4). Krause v. Commissioner, 92 T.C.
1003, 1024 (1989). Nevertheless, they are a factor to be
considered. Levien v. Commissioner, 103 T.C. at 126.
Respondent also contends that the deferral provisions
operated to protect decedent against loss. The sale or re-
leasing of the equipment at the end of the transactions, which
could have provided funds to satisfy deferred liabilities, was
viewed as a significant source of return on the investment. It
is clear that debt obligations payable in the future are included
in the amount for a which a partner is considered personally
liable for purposes of section 465(b)(2). Melvin v.
Commissioner, 88 T.C. 63, 73 (1987), affd. 894 F.2d 1072 (9th
Cir. 1990). Thus, we cannot simultaneously propose a rule that
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