- 6 - the lessor's rental income over the period of the lease exceeded the sum of the lessor's depreciation and cost of financing its purchase of the trucks. A typical lease transaction takes place as follows: Country-Fed first identifies the type of truck it wishes to lease. The lessor then obtains the truck that Country-Fed has identified. Often, Country-Fed negotiates with dealers regarding the price for which the lessor could acquire the truck. After identifying a truck which Country-Fed wishes to lease, Country- Fed and the lessor execute a "New Vehicle Order"4 which is subject to the terms of the master lease and contains the 3(...continued) (ii) which clearly and legibly states that the lessee has been advised that it will not be treated as the owner of the property subject to the agreement for Federal income tax purposes. (D) Lessor must have no knowledge that certification is false.--An agreement meets the requirements of this subparagraph if the lessor does not know that the certification described in subparagraph (C)(i) is false. As to each truck, Country-Fed executed the certification required by sec. 7701(h)(2)(C) and used the truck in its business. There is no evidence in the record regarding how the lessors financed their acquisition of the trucks. 4 This is the term used by the McCullagh master lease. The ARI master lease refers to this agreement as a "Motor Vehicle Lease Agreement". The World Omni master lease refers to this agreement as the "Leased Unit Quotation". Despite the difference in terminology, the information contained in each document is essentially the same.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011