- 6 - truck crash. Petitioner’s technical savvy served as a useful marketing edge in soliciting new work. Petitioner first began the leasing arrangement in 1992 by assigning law firm equipment to himself and leasing it to the law firm. He then purchased all future equipment personally and leased it to the law firm. The equipment petitioner leased to the law firm consisted of computers, video equipment, and office furniture.5 The original cost of the equipment used in the years at issue was $1,840,157. From 1992 through 1997, petitioner received rental payments from the law firm totaling $1,040,000. Petitioner intended to receive an amount in rent generally commensurate with the yearly depreciation deduction. During the years at issue, however, the law firm experienced a loss, and the law firm made no rental payments. Nor did the firm pay petitioner a salary in those years. The losses during those years were attributable to a case that petitioner had expected to close but that took until 2000 to close. Ultimately, petitioner’s leasing activity did not prove profitable, principally because of the losses during the years at issue, and he later sold the equipment to the law firm at book value for $557,885. The law firm paid petitioner by increasing the amount it owed him. 5The value of the office furniture was a small fraction of the value of the assets he leased to the law firm.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011