The so-called sale and lease-back device has long been the subject of judicial and governmental scrutiny. The Internal Revenue Service has recently decided to begin a more active campaign of enforcement against a certain three-party variation of the sale and lease-back device. The structure of this variation can be best understood by considering the following hypothetical situation.
Lawrence R. Velvel S.Ed.,
Taxation-Federal Income Taxation-The Three-Party Sale and Lease-back,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol61/iss6/23