Memorandum Opinion
TANNENWALD, Judge:
This case is before us on cross motions for entry of decision based on stipulations of settlement by the parties.
Insofar as is pertinent to these cross motions, the notice of deficiency in respect of the 1982 taxable year: (1) disallowed $157,500.00 of deductions in respect to OEC Leasing transactions (see Heasley v. Commissioner [90-1 USTC ¶ 50,314],
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