- 48 -                                        
                                           LII                                        
          1985      1986      1987      1988                                          
               EBIT/Interest       8.93      7.89       1.9      1.65                 
               EBITDA minus                                                           
               CAPEX/Interest       .94      (.77)    (7.81)    (1.16)                
                                           LTI                                        
                         1985     1986       1987                 1988                
               EBIT/Interest       7.14      3.38      1.82       1.50                
               EBITDA minus                                                           
               CAPEX/Interest     (4.04)    (3.92)    (6.15)     (1.19)               
               The ratios of EBIT to interest for Transit and Tree for the            
          years in issue were as follows:                                             
                         1985    1986       1987       1988                           
               Transit              2.66    1.98       1.59       1.06                
          Tree                  -      8.30       1.85       1.00                     
          I.   Bank Loans                                                             
               1.   Debt to Equity Ratios Required by Banks                           
               Petitioners' ability to borrow from commercial lenders was             
          limited by leverage ratios and other covenants included in the              
          loan agreements.18  The maximum that petitioners could borrow               
          under all of their commercial loan agreements without special               
          approval by the bank was the amount of debt that would not                  
          increase their debt to equity ratio to more than 2 to 1.  LTL,              
          LTI, LII, and LWSI had commercial loan agreements which required            
          them as the borrower or the guarantor to have debt to equity                
          ratios of 2.5 to 1 or less in the taxable years in issue.  The              
          GSX acquisition caused LII to be highly leveraged, which                    
               18 The banks could waive the debt to equity ratio limit.               
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