- 490 - E. IRA-1980 Foreign/Domestic Transaction ("Alfred Teves Transaction") A purported purchase agreement dated December 31, 1980, by and between Funding International and Funding Systems International GmBH (Funding GmBH) was consummated, pursuant to which Funding GmBH sold certain equipment to Funding International for $931,321, paid by a check in the amount of $18,721, and a nonrecourse note in the amount of $912,600. The schedule attached to the bill of sale with respect to the property contained duplicate schedules of certain equipment located in Belgium at two locations: One at Alfred-Teves Strasse, 3170 Gifhorn, and one at Muller Strasse, 4-14, 5275 Bergneustadt 1. All of this equipment is referred to as the Alfred Teves transaction. The $912,600 note executed by Funding International included a provision for deferral of payment by the payor, in the event amounts due for rent with respect to the lease between payor and payee were not made. The amount deferred would become payable on December 31, 1995, and would not accrue interest. The note was nonrecourse in that the payee looked solely to the collateral for payment of the obligation. Consistent with the agreement of purchase, Funding International and Funding GmBH entered into an agreement wherein the equipment was leased back to Funding GmBH.Page: Previous 480 481 482 483 484 485 486 487 488 489 490 491 492 493 494 495 496 497 498 499 Next
Last modified: May 25, 2011