SECTION 2. BACKGROUND

Section 4.01 of Rev. Rul. 55–540, 1955–2 C.B. 39, sets forth certain conditions that, in the absence of compelling factors of contrary implication, would warrant treatment of a transaction for federal income tax purposes as a conditional sales contract rather than a lease of equipment. See Rev. Rul. 55–541, 1955–2 C.B. 19; Rev. Rul. 55–542, 1955–2 C.B. 59; and Rev. Rul. 57–371, 1957–2 C.B. 214, for examples of transactions determined to be sales rather than leases. See Rev. Rul. 60–122, 1960–1 C.B. 56, for two transactions, one considered a lease and the other considered a sale. See also Rev. Rul. 72–408, 1972–2 C.B. 86, concerning the federal income tax consequences of a transaction cast in the form of a lease subsequently determined to be a sale.