Richard Taylor was born in Charlotte, Michigan on 5 November 1919. He received his A. B. from the University of illinois in 1941, his M. A. from Oberlin College in 1947, and his Ph. D. from Brown University in 1951. He has been William H. P. Faunce Professor of Philosophy at Brown University, Professor of Philosophy (Graduate Faculties) at Columbia University, and Professor of Philosophy at the University of Rochester. He is the author of about fifty articles and of five philosophical books. This volume consists of essays presented to Richard Taylor on the occa sion of his sixtieth birthday. Some of the contributors have been Taylor'S students; some have been his colleagues; and all have been, and continue to be, his admirers. I have made several attempts to articulate what it is I (I would not presume to speak for anyone else) admire about Richard Taylor: (1) There is a particular 'flavor' to Taylor's philosophical writing and con versation that is wholly delightful. Like any other flavor, it can be tasted and enjoyed and remembered but never adequately described. (If there should be someone who has picked up this book who does not know what I mean, I recommend that he read the chapter on 'God' in Taylor's Metaphysics. ) (2) Taylor is a masterful dialectician.

Volume of the United States Tax Court Reports containing case abstracts and opinions of the court regarding cases between July 1, 2013 December 31, 2013. Cases in each volume are listed in the prefatory table. The United States Tax Court is a federal trial court of record established by Congress under Article I of the U.S. Constitution, section 8 providing (in part) that Congress has the power to "constitute Tribunals inferior to the Supreme Court. “The Tax Court specializes in adjudicating disputes over federal income tax, generally prior to the time at which formal tax assessments are made by the Internal Revenue Service. Though taxpayers may choose to litigate tax matters in a variety of legal settings, outside of bankruptcy, the Tax Court is the only forum in which taxpayers may do so without having first paid the disputed tax in full. Parties who contest the imposition of a tax may also bring an action in any United States District Court, or in the United States Court of Federal Claims; however these venues require that the tax be paid first, and that the party then file a lawsuit to recover the contested amount paid (the "full payment rule”).” Contents 8 Findings of Fact 8 Background 8 John Hancock’s History9 Investment Process and Review10 Leasing10 LILO and SILO Transactions 10 Basic Structure 15 History 17 Due Diligence 18 The Hoosier Transaction 19 The LILO Test Transactions 20 OBB LILO20 Lease and Sublease23 End of Sublease Term25 SNCB 2 and SNCB 5 Lot 1 LILO Transactions25 Lease and Sublease28 End of Sublease Term 28 The SILO Test Transactions 29 TIWAG29 Lease and Sublease33 End of Sublease Term35 Two Dortmund Transactions35 Lease and Sublease38 End of Sublease39 SNCB SILO39 Grant and Subgrant42 End of Subgrant Term 43 Tax Returns, Notices of Deficiency, and Trial 43 Procedural History48 Trial 53 Opinion 53 Burden of Proof53 Principal Place of Business54 Leveraged Lease Transactions54 Frank Lyon58 LILO and SILO Litigation 77 The Test Transactions 78 Economic Substance79 Objective Inquiry88 Subjective Inquiry89 Substance Over Form91 OBB and SNCB LILO Transactions110 SILO Test Transactions 145 Interest Deductions 147 Original Issue Discount 149 Transaction Expenses 149 Conclusion NOTE: NO FURTHER DISCOUNTS FOR ALREADY REDUCED SALE ITEMS. Keywords: tax court reports, reports of the united states tax court, u.s. tax court reports, united states tax court reports, united states tax court, u.s. tax court, tax court