William and Arlene G. Kingston - Page 6

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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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