- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011