U.S. Income
Tax Law

Toby Cozart 

Attorney at Law         


Lease Modeling Expertise

    Since the mid 1990’s, Mr. Cozart has modeled a variety of lease transactions using leading software programs for pricing leasing and partnership transactions. He has focused extensively on partnership leasing structures, joined together with the latest techniques for satisfying the rental income accounting rules under IRC §467, including rent loans. He has also developed models to confirm the assumptions used in pricing new and restructured conventional lease transactions.

    In the typical big-ticket leveraged leasing transaction, rent and debt service is optimized using linear programming techniques to increase the lessor’s after-tax yield (or the lessee’s financial benefit) by reducing or eliminating sinking funds. The partnership leasing models require additional complexity associated with the relative investments and cash flows of the partners and their separate tax positions and after-tax yield requirements, as well as complex additional tax and accounting requirements.

    In designing a partnership leasing transaction, lease termination value payments must be made acceptable to the lessee. Upon a default by the lessee, these values need to preserve the anticipated after-tax returns of the partners in the lessor partnership, including by reversing the tax-based partner’s capital account deficit. See Leasing Partnerships.  In many transactions, these values may be lowered in the early years of the lease transaction to acceptable levels by using a variety of optimization techniques.

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