- 11 -
Casebeer v. Commissioner, 909 F.2d 1360, 1363 (9th Cir.
1990), affg. in part, revg. in part and remanding T.C.
Memo. 1987-628, Larsen v. Commissioner, 89 T.C. 1229
(1987), Sturm v. Commissioner, T.C. Memo. 1987-625,
Moore v. Commissioner, T.C. Memo. 1987-626; Sochin v.
Commissioner, 843 F.2d 351, 354 (9th Cir. 1988), affg.
Brown v. Commissioner, 85 T.C. 968 (1985); Rice's Toyota
World, Inc. v. Commissioner, 81 T.C. 184, 201-204 (1983),
affd. in part, revd. in part, and remanded 752 F.2d 89
(4th Cir. 1985).
On the basis of all of the facts and circumstances
presented, we found that petitioner's purchase of an
interest in the Trust was without economic substance.
That finding was based upon factors commonly reviewed
in determining whether a computer leasing transaction
possesses economic substance, including the presence or
absence of arm's-length price negotiations, the reason-
ableness of the income and residual value projections,
the structure of the financing, the degree of adherence
to contractual terms, and, of particular significance in
this case, the relationship between the sale price and
fair market value of the property acquired. See Levy v.
Commissioner, 91 T.C. 838, 856 (1988). In considering the
last factor, we took note of "the limited nature of the
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