-419-
misguided in their attempt to bootstrap this issue with that of
the HGA Cinema Trust case regarding the SLG Partners computer
sale/leaseback transaction. SLG Partners was a separate and
distinct entity from GLS Associates, and the SLG Partners
computer sale/leaseback transaction was a separate and different
transaction from the GLS Associates transaction. It was
incumbent on petitioners to introduce pertinent evidence on the
GLS Associates transaction, as opposed to merely arguing that the
GLS Associates transaction was essentially the same as the SLG
Partners transaction. Petitioners failed to produce any evidence
on this issue, and their self-serving legal arguments on brief do
not constitute evidence. Consequently, the Court sustains
respondent’s determination on this issue. See Rule 142(a).161
161 The Court also finds petitioners’ seeming reliance upon
HGA Cinema Trust v. Commissioner, T.C. Memo. 1989-370, affd. 950
F.2d 1357 (7th Cir. 1991), curious, as petitioners are not
arguing that this Court should reach a conclusion similar to its
conclusion therein. In HGA Cinema Trust, this Court, among other
things, determined that certain long-term promissory notes SLG
Partners issued in connection with the purchase of computer
equipment were not valid indebtedness. The taxpayer in HGA
Cinema Trust was a trust that was a limited partner in SLG
Partners. Kanter was the trust’s trustee and also its counsel in
the litigation before this Court and the U.S. Court of Appeals
for the Seventh Circuit. Moreover, in the instant cases,
although there originally had been certain adjustments at issue
between the parties relating to SLG Partners and K&D Associates
(which latter entity, according to petitioners, simply held an
interest in SLG Partners), those adjustments were settled by the
parties. On May 15, 1995, the parties filed with the Court their
stipulation of settlement as to certain issues between the
Kanters and respondent. Pursuant to the May 15, 1995,
stipulation of settlement, petitioners generally conceded the
underlying SLG Partners and K&D Associates adjustments, except
(continued...)
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