- 27 - $1,982,825. The $1,982,825 rental deduction, in conjunction with other items on petitioner’s 1995 Federal return, resulted in a $404,000 net operating loss (NOL) carryover from the 1995 to the 1996 tax year. Respondent, in the notice of deficiency, disallowed the $404,000 NOL carryover. 7. On October 31, 1996, CMACM transferred 25 percent of its interests and obligations in the Shared end-user lease to First Lexington Leasing, Inc. (Lexington). From 1998 to the time of trial Lexington was owned by Asset Leasing Partners I, LP, with Crispin and CMACM as managing general partners and the Iowa Tribe as a limited partner. Among other things, CMACM transferred: (1) Twenty-five percent of CMACM’s rights in the Shared equipment, and (2) 25 percent of that portion of the Jenrich note attributable to the Shared equipment. In exchange for CMACM’s transfer, Lexington issued a $10,000 unsecured promissory note to CMACM and assumed 25 percent of that portion of CMACM’s over lease rental payment obligation to Jenrich attributable to the Shared equipment. The promissory note had an 8-percent interest rate and was due on December 31, 2002. Lexington was incorporated in California during 1995 and was wholly owned by Richard Koehler (Koehler), a friend and longtime business associate of Crispin. Before and after the CMACM- Lexington transaction, Koehler depended on petitioner and Crispin for funds to keep CMA Capital Corp. operating.Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
Last modified: May 25, 2011