- 15 -
Commissioner, 87 T.C. 970, 976 (1986); the structure of the
financing, Helba v. Commissioner, supra at 1007-1011; whether
there was a shifting of the burdens and benefits of ownership,
Rose v. Commissioner, 88 T.C. 386, 410 (1987), affd. 868 F.2d 851
(6th Cir. 1989); the degree of adherence to contractual terms,
Helba v. Commissioner, supra at 1007-1011; and the reasonableness
of the income projections, Rice's Toyota World, Inc. v.
Commissioner, 81 T.C. 184, 204-207 (1983), affd. in part, revd.
in part and remanded 752 F.2d 89 (4th Cir. 1985).
Petitioners presented no pertinent evidence regarding their
equity in Oshtemo-Kalamazoo or the prospect of economic success
beyond very conclusory assertions that Mr. Weiss thought that
investing in a cable television system would be profitable. They
gave no hint as to the content or nature of any negotiations
employed in acquiring the property, nor did they establish the
sale price or the actual value of the assets at issue. As to the
structure of the financing, we are told only that Oshtemo-
Kalamazoo issued a note to acquire a cable television system in
1976. The note was nonrecourse, and petitioner Abraham Weiss did
not have personal liability on the note. This information is not
particularly instructive as to the issue of profit objective.
Petitioners have given us no specifics as to any shifting of
the burdens and benefits of ownership, except for our being told
that an entity named Acton CATV acquired the assets some years
after those in issue. Nor have they provided information
regarding the degree of adherence to contractual terms or the
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