The New York State Department of Taxation and Finance has determined that agreements for the transfer of non-vehicle equipment to customers were security agreements, and therefore resulted in outright sales of the equipment, rather than true leases, so that the full amount of sales tax should be collected at the outset of the lease. Advisory Opinion, TSB-A-13(5)S N.Y.S. Dep’t of Taxation & Fin., Jan. 24, 2013). Although one agreement provided that the lessee has the option of returning the equipment or purchasing it for $1, and in the second the lessee is required to purchase the equipment for $1, both agreements were found to be security agreements under the definitions contained in U.C.C. section 1-201(37), because the lessees were either required to become the owners of the equipment or had the option to become the owners for nominal consideration.