- 58 - Before November 1994, CLI (an entity unrelated to petitioner) owned certain computer, photo processing, and satellite dish equipment that was leased to various entities unrelated to petitioner. Most of these existing leases were scheduled to end during the spring, summer, or winter of 1997. In late 1994 and early 1995, petitioner arranged a first lease strip deal for CFX. According to a tax opinion, CFX, in exchange for a cost of approximately $2.9 million, would receive approximately $13.8 million in deductions. The $2.9 million to be paid by CFX was divided among the participants and others who arranged the deal, including CLI and petitioner. Petitioner earned $611,655 for its services in arranging the first lease strip deal for CFX. A second lease strip deal involving some of the same equipment was initiated approximately 9 months later. In the first and second lease strip deals there were at least 17 interrelated transactions with respect to the same equipment. Under the second lease strip deal, petitioner claimed over $4.2 million in deductions for 1995, 1996, and 1997. Petitioner’s out-of-pocket cost for the “investment” in its second lease strip deal approximated 1 percent of the claimed deductions or slightly more than $40,000.Page: Previous 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 Next
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