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tax provision enacted as part of the Economic Tax Recovery Act of 1981 to guarantee sale/leaseback treatment to certain transactions if specific requirements are met. The purpose of this provision was to make it easier for loss companies to "sell" their tax benefits accruing on new asset purchases by entering into sale/leaseback transactions with profitable companies. The intent was to generate an immediate cash flow for such loss companies, rather than deferring the benefits through carryover provisions.