Chiagkouris v. 201 W. 16 Owners Corp.

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• respecting sale/leaseback because taxpayer “bore risk” that it could not “recoup its cash outlay.”
• finding a residual value equal to the stipulated residual value of at least 14 percent, rather than equal to the maximum of a range of 20 to 30 percent projected by the taxpayer's experts
• “[T]he parties’ characterization of the form of the transaction should be respected so long as the lessor retains significant and genuine attributes of a traditional lessor.”
• amortization of partnership syndication expenses disallowed under law prior to the effective date of section 709
• amortization of partnership syndication expenses disallowed under law prior to the effective date of section 709
• \We have found * * * that a profit was reasonably likely so that the economic substance test has been fairly met.\

Source: CourtListener parenthetical corpus (CC0).