- 3 -
Held, further, alternatively, participation of BP,
FBE, and EICI in the sale-leaseback transaction described
above is disregarded under the step transaction doctrine.
Held, further, the sale-leaseback transaction
described above lacked a valid business purpose, as well
as economic substance, and thus is not to be respected
for Federal tax purposes. Consequently, (1) A is not
required to include the sale of the rents ($87,805,801)
as income for the 12/31/93 short period, (2) A is not
entitled to deduct $2,143,937 as expenses from “other
rental activities” for the 12/31/93 short period, and (3)
A is not entitled to deduct $50,069,397 of similar
expenses for 1994.
Mark Alan Hager, Walter A. Pickhardt, John R. Kalligher,
William K. Wilcox, and Myron L. Frans, for petitioners in
docket No. 15532-98.
Walter A. Pickhardt, Mark Alan Hager, and William K.
Wilcox, for petitioner in docket No. 4277-00.
Walter A. Pickhardt, for petitioner in docket No. 6348-00.
Robert M. Ratchford, Donna C. Hansberry, John C. Schmittdiel,
and Robert J. Burbank, for respondent.
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