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installment payments of $153,212 each, with the first payment due
on March 31, 1986. This note was nonrecourse as to the
partnership.3 In conjunction with the partnership's purchase of
the Initial Equipment, Hambrose assigned to the partnership the
Initial Equipment Wrap Lease, as a result of which the four
consecutive annual rent payments of $153,212 each would be paid
to the partnership by Charterhouse.
The Additional Equipment
CIS and Comdisco financed, on a nonrecourse basis, the
purchase of certain additional IBM computer equipment (the
Additional Equipment) for a total purchase price of
$18,019,633.11.4 They financed the purchase of this Additional
Equipment through six different third-party lenders and leased
the Additional Equipment to six different end users.
Charterhouse purchased the Additional Equipment from CIS and
Comdisco in two separate purchase transactions, one each for the
Additional Equipment under each user lease. The total purchase
price for all the Additional Equipment was $15,643,832, of which
3 Hambrose Leasing v. Commissioner, 99 T.C. 298, 301, 312
(1992).
4 The parties stipulated that this $18,019,633.11 represented
the total amount financed through third party lenders for the
purchase of the Additional Equipment. Since there is no
indication from the record that any cash, or other funds, was
paid to acquire the Additional Equipment, the Court surmises that
the total amount financed represented the total purchase price of
the Additional Equipment.
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