John Hancock Life Insurance Company (U.S.A.), as Successor in Interest to John Hancock Life Insurance Company v. Commissioner

Haines, Judge:

These cases are consolidated for purposes of trial, briefing, and opinion. Respondent determined the following deficiencies in petitioners’ Federal income tax for 1994 2 and 1997-2001 (years at issue): 3

Year Deficiency

1994 . $8,860,564

1997 . 65,746,621

1998 . 173,497,367

1999 . 59,899,141

2000 . 108,046,947

2001 . 143,516,079

These deficiencies stem from 27 leveraged lease transactions (leveraged leases) that petitioners participated in between 1997 and 2001. For purposes of resolving this action expeditiously, the parties agreed to try seven of the leveraged leases (test…