documents are not rigidly binding,” id. at 573, 98 S.Ct. 1291, so that the Court would not condone “manipulation by a taxpayer through arbitrary labels and dealings that have no economic significance,” id. at 583, 98 S.Ct. 1291. Thus, the Court ruled, a taxpayer can safely treat leases as genuine for tax purposes only if the taxpayer “retains significant and genuine attributes of the traditional lessor status.” Id. at 584, 98 S.Ct. 1291. Similarly, the Uniform Commercial Code (“UCC”), widely adopted during the 1960s, defined “security interest” as including financing agreements in the form of personal property leases. Section 1-201(37) of the 1958 Official Text of the UCC provided, in part: Unless a lease ... is intended as security, Vita Fruit Co.), 473 F.2d 585, 589 (6th Cir.1973) (<HOLDING>); Louis F. Del Duca, Evolving Standards for
holding that the damage for tenancy at sufferance during the holdover period was the monthly rent under the lease versus the apartments fair market value because the lease contained a provision requiring lease payments beyond the lease term holding that former employees of a brokerage firm who had a contractual right to a share of any commission received by the firm upon extension of a lease were not entitled to a share of the commission received when the landlord and tenant entered an amendment to the lease which extended the duration but also added new terms this was a new lease not an extension of the prior lease holding lease agreement that explicitly stated it was finance lease as defined in article 2a of ucc was finance lease even though lessee did not direct lessor to acquire goods or right to possession and use of goods from supplier holding in a reclamation action against a bankruptcy trustee that the determination of whether the lease instruments were true leases or security agreements is critical holding that the question of whether a bankruptcy trustee or a putative lessor was entitled to the proceeds of an equipment sale depended on whether a true lease was involved when the lease is intended as a security interest article 9 applies however a bona fide lease is not affected by article 9