- 498 - or business purpose and were only part of the transactions for Federal tax purposes. H. Cedilla Invest. "Dard Systems Transactions" On December 22, 1986, Cedilla Invest. purportedly purchased certain IBM-manufactured computer equipment from Dard Systems, Inc. (Dard), for $3,615,100. Prior thereto, on June 29, 1981, Funding Systems International had sold this equipment to Equitable Leasing Co., and on the same date, Equitable Leasing Co. had leased the equipment back to Funding Systems International. Equitable Leasing Co., on September 30, 1981, sold the equipment to Dard, and thereafter Dard sold the equipment to Cedilla Invest. on December 22, 1986, subject to several end user leases with various entities in England as well as the lease encumbering the equipment in favor of Funding Systems International. The stated purchase price of $3,615,100 was, according to the terms of the purchase agreement, to be paid by Cedilla Invest. to Dard as follows: $18,000 cash payable at the time of the execution of the agreement; a short-term promissory note payable on May 15, 1987, in the amount of $198,000; and a long- term, "limited recourse" promissory note in the amount of $3,399,100. Under the terms of the "limited recourse promissory note", Cedilla Invest. was personally liable only during the times andPage: Previous 488 489 490 491 492 493 494 495 496 497 498 499 500 501 502 503 504 505 506 507 Next
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