Harry E. Peaden, Jr. - Page 9




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          arranging the sale, the lessor is required to remit the excess to           
          Country-Fed.  If the proceeds of the sale obtained by the lessor            
          are less than any remaining base rent, plus the cost to the                 
          lessor of arranging the sale, Country-Fed is required to pay the            
          lessor the difference.                                                      
               The McCullagh master lease contains an option for Country-             
          Fed to buy the respective truck at the end of its lease term for            
          the truck's fair market value.  The ARI master lease specifically           
          provides that Country-Fed has no option to purchase the                     
          respective truck at any time.  The World Omni master lease does             
          not provide an option for Country-Fed to buy the respective truck           
          but provides that Country-Fed may purchase the truck if it is               
          being sold at a public sale.  Country-Fed did, however, acquire             
          title to most of the trucks at the end of the respective lease              
          transactions.                                                               
               On or about April 9, 1997, respondent issued a notice of               
          deficiency that determined a deficiency in petitioners' Federal             
          income tax in the amount of $977,267 for their 1993 taxable year.           
          Respondent increased petitioners' Schedule E income by                      
          $2,304,296.  In calculating the increase, respondent determined             
          that petitioners were not entitled to:  (1) A rental deduction of           
          $2,946,224 for the lease of trucks and related equipment by                 
          Country-Fed; (2) an employee business relations/entertainment               
          deduction of $222,425; and (3) other deductions of $350,365.                





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