William and Arlene G. Kingston - Page 3

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            Petitioners filed joint Federal income tax returns for 1985                               
            and 1986.  On their returns, petitioners claimed deductions of                            
            loss and investment interest expense (the claimed deductions)                             
            relating to Hambrose Leasing 1985-3 (the partnership) in the                              
            following amounts:                                                                        
            Year              Loss                    Investment Interest Expense                     
            1985              $13,903                             $1,082                              
            1986              21,538                              2,190                               
                  This case involves two sale-leaseback transactions among the                        
            following entities:  CIS Leasing Corp. (CIS), a New York                                  
            corporation with principal offices in Syracuse, New York;                                 
            Comdisco, Inc. (Comdisco), a Delaware corporation with principal                          
            offices in Rosemont, Illinois; Charterhouse Leasing Associates                            
            Limited Partnership (Charterhouse), a Connecticut limited                                 
            partnership; Hambrose Reserve Ltd. (Hambrose), a Delaware                                 
            corporation; M & J Holding Corp. (M & J), a Delaware corporation                          
            that was the sole shareholder of Hambrose and the general partner                         
            of Charterhouse; and Hambrose Leasing 1985-3 (the partnership), a                         
            partnership engaged in the equipment leasing business.                                    
            The Sale-Leaseback Transactions                                                           
                  The transactions can be described in general terms as                               
            follows:  CIS and Comdisco purchased IBM computer equipment with                          
            a specified amount of borrowed funds.  CIS and Comdisco then                              
            leased the computer equipment to various end users.  CIS and                              
            Comdisco then sold the computer equipment to Charterhouse,                                




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