CMA Consolidated, Inc. & Subsidiaries, Inc. - Page 92

                                       - 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

Last modified: May 25, 2011