- 529 - In view of the foregoing, IRA is not entitled to any deductions, credits, or losses associated with these purported transactions. G. Equitable Leasing This is another computer leasing transaction purportedly engaged in by IRA. A reference is made to it in the summary schedules of a witness for IRA. While respondent does not agree with the numbers delineated in the summary schedules, it appears that this transaction was considered in computing the tax liability of IRA for the taxable year ended December 31, 1980. No facts to support the basis for the income, deductions, credits, or losses, which apparently were claimed in connection with this transaction, were presented by IRA. Since IRA had the burden of proof on this issue, we sustain respondent's determinations of disallowance with respect to this transaction. Finally, the long-term promissory notes executed by IRA to finance the purported computer sale and leaseback transactions do not constitute valid indebtedness because there was little possibility that IRA would ever be required to make the payments due. IRA's long-term promissory notes in these various transactions were neither unconditional nor enforceable. They are not unconditional because the promise to pay in most of the notes was expressly contingent, by virtue of the deferralPage: Previous 519 520 521 522 523 524 525 526 527 528 529 530 531 532 533 534 535 536 537 538 Next
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