Abstract: The Tax Equity and Fiscal Responsibility Act of 1982 substantially modified the "safe harbor'' leasing provisions enacted by the Economic Recovery Tax Act of 1982. In this Comment, Professors Warren and Auerbach argue that the modifications did not remedy the defects they identified in an earlier Article and that a new category of "finance leases" may prove to be nearly as valuable for some taxpayers as were safe harbor leases before the 1982 changes.