- 30 - On July 20, 1998, CMACM redeemed the 10 shares of CMACM common stock held by CAP for $500. On its return for its taxable year ended November 30, 1998, petitioner wrote off and deducted the $10,000 and $1,000 Lexington notes issued to CMACM in the CMACM-Lexington transactions. In the second lease strip deal, the over lease residual interests in the K-Mart and Shared equipment were the sole source of possible cashflow and pretax profit to petitioner. About 2 months after CMACM obtained the over lease residual interests from CAP, CMACM transferred the over lease residual interest in the K-Mart equipment to Okoma. On October 31, 1996, CMACM transferred 25 percent of its over lease residual interest in the Shared equipment to Lexington. As previously noted, upon termination of the Shared end-user lease (March 29, 1997), the Shared equipment was to be returned to CLI. On September 1, 1997, CMACM transferred the remaining 75 percent of its over lease residual interest in the Shared equipment to Lexington. For 1998, petitioner wrote off the $10,000 and $1,000 Lexington notes that CMACM earlier received in exchange for CMACM’s residual lease interest in the Shared equipment. Christopher Hughes (Hughes), petitioner’s manager for tax and accounting, concluded, among other things, that Lexington’s lease position in the Shared equipment was worthless.Page: Previous 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 Next
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