- 9 - 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.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