- 59 - The first lease strip deal (for CFX) and the second lease strip deal (for petitioner) involved equipment already subject to the following leases: (1) A lease of photo processing equipment to K-Mart (a large retailer), and (2) a lease of computer equipment to Shared (a medical services provider). Late in 1994, the K-Mart and Shared leases each had only a few years left to run. The transactions used to effect the first lease strip deal included: (1) The purchase of computer, photo processing, and satellite dish equipment already subject to existing end-user leases with K-Mart, Shared, and others; (2) “taxable sale”- leaseback transactions of that equipment by CFP, a partnership and a tax-indifferent partner under the sale-leaseback partnership, (a) where CFP was issued an equipment purchase installment note with the installments equal to and offset by the rental payments due under the wraparound lease entered into by CFP, and (b) CFP’s leaseback of that equipment under a wraparound lease encompassing those existing end-user leases; (3) a lease strip sale by CFP whereby virtually all of the rental income with respect to those existing end-user leases was stripped out and allocated to the Iowa Tribe, a tax-indifferent party and 99- percent limited partner of CFP; and (4) the transfer in aPage: Previous 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 Next
Last modified: May 25, 2011