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voting stock and that Cedilla Invest. was included in IRA's
consolidated tax returns for those years.
Kanter was the attorney for IRA and investment adviser with
respect to its computer leasing transactions. No one employed by
IRA was responsible for negotiating the equipment leasing deals
except Kanter, who assumed responsibility for them. IRA did not
utilize the services of experts in computer equipment in
connection with any of the computer equipment leasing
transactions that were consummated during the years in question.
In notices of deficiency to IRA, respondent determined that
IRA was not entitled to deductions and credits with respect to
various computer equipment leasing transactions during the years
at issue.
Respondent made the following adjustments to IRA's Federal
income tax returns in connection with its equipment leasing
transactions:
Year Rent Income Depreciation Interest Expense
1980 ($830,964) $2,353,776 $1,027,510
1983 (2,581,652) 1,632,456 1,732,404
1984 (2,689,177) 1,743,556 1,628,589
1985 (2,689,177) 1,219,280 1,495,916
1986 2,151,377 1,850,912 701,824
1987 2,587,958 –- --
1988 1,633,794 –- --
1989 1,406,784 –- –
Respondent disallowed the following investment tax credits
claimed by IRA relating to the equipment leasing transactions:
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