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applicable only to existing leases that are to continue in
futuro. In addition, the existing case precedent is in harmony
with section 167(c)(2) by not permitting allocation of a portion
of the purchase price of a leased asset to the value or cost of
the lease.
Accordingly, we hold that section 167(c)(2) applies to
petitioner’s acquisition of the vessel, and respondent’s Motion
for Partial Summary Judgment will be granted.
An appropriate order will be
issued.
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