7 pgs) Enclosure 1 C NBAFI NBAA Explanation of Why Treasury and the IRS Aro Not Barred From Implementing a "Look- Through" Approach With Regard to the Treatment of Leasing Activity under I.R.C. § 280F(b) As detailed in the legislative history, one of the criginal purposes of enacting § 280F. as part of the Tax Reform Act of 19