- 19 - transactions. On April 28, 2000, CFX Financial redeemed its preferred stock held by CFP for $94,950.82, consisting of $75,000 for the shares and $19,950.82 in dividends thereon. C. Second Lease Strip Deal Sometime before August 1995, Crispin asked Klein and certain parties and/or entities involved in the first lease strip deal to create another position out of the equipment package involved in that first deal. Although petitioner and Crispin were planning to market this second lease strip deal to a customer, they changed their plans following the Internal Revenue Service’s (IRS) issuance of Notice 95-53, 1995-2 C.B. 334, on October 30, 1995. In Notice 95-53, supra, the IRS warned it would challenge and disallow potential tax benefits that taxpayers claimed under lease strip deals. Due to the issuance of Notice 95-53, supra, petitioner and Crispin concluded that it would not be possible to sell the second lease strip deal to third parties. Because the transactions for the contemplated deal had already been consummated, petitioner and Crispin instead decided to complete the second lease strip deal with petitioner as the “customer” or ultimate beneficiary. The wraparound lease (over lease) in the second lease strip deal involved the K-Mart and Shared end-user lease equipment and encompassed the existing K-Mart and Shared end-user leases. However, the express lease term for the K-Mart and Shared overPage: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
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