- 29 - also deducted $237,853 (which was equal to the amount due CMACM from Jenrich under the Jenrich installment note) as over lease rental payments that it claimed to have paid to Jenrich during 1997. D. Other Aspects of Petitioner’s Claimed Losses and Deductions With Respect to the Second Lease Strip Deal As a result of the second lease strip deal and CMACM’s partial dispositions of the Jenrich note over a 21-month period, petitioner claimed more than $4.2 million of deductions for 1995, 1996, and 1997. Petitioner did not report any income from Okoma’s and Lexington’s assumptions of CMACM’s over lease rental payment obligations to Jenrich. In addition to $3,620,059 of losses claimed for dispositions of the Jenrich note, petitioner claimed deductions of $414,041 (1996) and $237,853 (1997) for over lease rental payments to Jenrich. In almost all of the above-described second lease strip deal transactions, petitioner either received or was entitled to receive an offsetting payment equal to the amount it was obligated to pay and deducted. In only one instance, involving the purported section 351 transfer, did petitioner assume $215,000 of the $750,000 CAP note owed to EQ, without receiving or being entitled to receive an equivalent offsetting amount.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
Last modified: May 25, 2011