20 April 2009 External T.I. 2008-0303651E5 - Tax Implications of Leasing Arrangements -- summary under Depreciable Property

A purchase option will not result in the optionholder being considered to have acquired the property where there is no obligation on the part of that person to assume ownership of the property at the expiration of the lease arrangement. "In our view, if a lease is, at law, a lease, then it will be treated as a lease for all purposes of the Act."