During the 2020 taxable year, Leasing Corp. (a "C" corporation all of the stock of which was owned throughout the year by the same four individuals) purchased computer equipment which it then leased to unrelated third parties. During 2020, Leasing Corp. had ten full-time employees, three of whom devoted 100% of their time to the leasing activities engaged in by Leasing Corp. Leasing Corp. had total gross receipts for the year 2020 equal to $27,000,000 and $14,000,000 of this amount was attributable to its 25 leasing transactions. On January 1, 2020, Computer A1001 was purchased for $3,000,000. LEASING Corp. paid $250,000 in cash for the computer and executed a non-recourse note in the amount of $2,750,000