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The Investment Memorandum also states:
Except for the Trustee's right to collect
the Additional Rent [i.e., Contingent Rent], any
ultimate economic return to the Unitholders is
dependent upon the residual value of the Equip-
ment, if any, at the expiration of the terms of
the [Master] Leases.
OPINION
This case involves a garden-variety computer leasing
tax shelter similar to others that the Court has held to be
shams. See Estate of Strober v. Commissioner, T.C. Memo.
1992-350; Mele v. Commissioner, T.C. Memo. 1988-409;
Dobbs v. Commissioner, T.C. Memo. 1987-361; cf. Rubin v.
Commissioner, T.C. Memo. 1989-484. There is nothing novel
in the transaction or the Court's opinion in response to
it. In Robertson I, we held that petitioners had failed
to meet their burden of proving that the subject sale-
leaseback transaction was not a sham as had been determined
by respondent. We considered both the economic substance
of the transactions, i.e., whether they offered a reason-
able opportunity for profit exclusive of tax benefits, and
petitioner's subjective business purpose for entering the
transactions, i.e., whether he had a profit objective or
purchased an interest in the trust solely to acquire tax
benefits. See generally Gilman v. Commissioner, 933 F.2d
143, 147-148 (2d Cir. 1991), affg. T.C. Memo. 1990-205;
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