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OPINION
On brief, petitioners acknowledge there is no specific
evidence in the record establishing the existence of a computer
leasing transaction by GLS Associates Partnership out of which
the claimed loss arose. However, petitioners contend there is
evidence in this record with respect to other computer leasing
transactions entered into by other entities, arguing on brief:
The record is replete with evidence regarding [certain]
computer sale/leaseback transactions [of other
entities]; otherwise neither party submitted any
evidence with respect to * * * [GLS’ computer
sale/leaseback] transaction except that the parties
have both introduced argument and information
pertaining to the case of HGA Cinema Trust v.
Commissioner, T.C. Memo. 1989-370, affd. 950 F.2d 1357
(7th Cir. 1991) * * *.
Petitioners maintain the GLS Associates computer sale/leaseback
transaction was “essentially the same in substance and form” as
the SLG Partners computer sale/leaseback transaction considered
by this Court in HGA Cinema Trust v. Commissioner, T.C. Memo.
1989-370, affd. 950 F.2d 1357 (7th Cir. 1991). Petitioners
appear to refer to evidence presented in connection with an IRA
computer equipment leasing transaction as proof they are entitled
the loss they claimed with regard to GLS Associates.
Respondent, on the other hand, contends petitioners failed
to carry their burden of proof under Rule 142(a).
Petitioners failed to propose any findings of fact on this
issue in their posttrial opening brief. Petitioners are
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