The IRS may charge you a user fee for issuing a tax ruling. For more information, see Revenue Procedure 2001-1, in Internal Revenue Bulletin No. Leveraged leases of limited-use property. Limited-use property is property not expected to be either useful to or usable by a lessor at the end of the lease term except for continued leasing or transfer to a lessee. Special rules are provided for certain leases of tangible property.
Rents increase during the lease.
Rents decrease during the lease. In addition, in certain cases in which the IRS has determined that a lease was designed to achieve tax avoidance, you must take rent and stated or imputed interest into account under a constant rental accrual method in which the rent is treated as accruing ratably over the entire lease term. For details, see the regulations under section 467 of the Internal Revenue Code.