disqualified leaseback or long-term agreement
(4) Disqualified leaseback or long-term agreement For purposes of this subsection, the term “disqualified leaseback or long-term agreement” means any section 467 rental agreement if— (A) such agreement is part of a leaseback transaction or such agreement is for a term in excess of 75 percent of the statutory recovery period for the property, and (B) a principal purpose for providing increasing rents under the agreement is the avoidance of tax imposed by this subtitle.