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Term of the lease It is a lease or an exchange?
Option to purchase back Is it at fair market
ABC Transaction Annual Rant basis building buyer buyer-lessor cash flows CCH Dec Commissioner depreciation and interest disallowed donor donor-lessee economic substance entitled to deduct example exchange and leaseback fair market value Frank Lyon gift and leaseback ground lease interest deductions investor Jordan Marsh lease term leaseback property leaseback with option lessee lessor loan Ml Ml Ml mortgage MT Ml non-deductible nonrecourse financing option price option to repurchase ordinary income original cost owner ownership partnership Present Value Discounted primary term property back purchase price Rate of Return Ravaralon Tleld Ravaralon Realtor related parties rent rental deduction rental income rental paid residual value Reversion Tleld Reversion sale and leaseback sale price sale-leaseback sell seller seller-lessee Sun Oil Supreme Court tax avoidance tax benefit Tax Court tax purposes tax savings tax shelters taxable taxpayer Tield tion Tlald Tleld Ravaralon Tleld Tleld Reversion Tleld TM TM ustc Worthen