- 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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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