CMA Consolidated, Inc. & Subsidiaries, Inc. - Page 64

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               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.                                         








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