Investment Research Associates - Page 429




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          I.B.M. model 3031 and other equipment; and (3) Cheshire County               
          Council 6�-year lease for an I.B.M. model 3031, and other                    
          equipment.  The entities named were the end users of the computer            
          equipment which had been purchased on or about October 10, 1979.             
               Under the agreements between Atlantic, European, Carena, and            
          Funding International, Atlantic transferred to Carena, and Carena            
          to Funding International, the interests of Atlantic in the                   
          computers used by the end users.  With respect to this                       
          transaction, Funding International executed, in favor of Carena,             
          a nonnegotiable, nonrecourse promissory note in the amount of                
          $1,403,601 dated October 31, 1979.                                           
               On October 31, 1979, an agreement of lease was executed by              
          and between Funding International and Carena, leasing the                    
          property back to Carena.                                                     
               The sale and purchase agreement between Atlantic, European,             
          Carena, and Funding International allowed European to sell,                  
          transfer, and assign to Carena all of Atlantic's interest in the             
          equipment.  Atlantic would own the equipment subject to the lease            
          only upon repayment of the repurchase price specified in the                 
          residual agreement.  Atlantic, therefore, did not have legal                 
          title to the property as of October 31, 1979, but agreed to                  
          obtain legal title after the original end user lease expired.                
               Under the sale and purchase agreements, Atlantic and                    
          European agreed to deliver to Carena the instruments Carena                  






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