The Tax Court held that a taxpayer who purchased solar panels installed on host properties, and who acquired rights under agreements with the host property owners to provide electricity contingent on receiving tax credits and other incentives, had a basis in the solar equipment equal to the amount of a promissory note that partially financed the purchase but could not include in his basis a down payment that was never made, nor a credit for rebates that the host property owners assigned to the previous solar panel owner before the sale.

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