Investment Research Associates - Page 474




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          principal and interest, due under the note, if any amount of rent            
          due under the lease was not received by the payor as the payments            
          became due.  The deferral allowed the payor, Cedilla Invest., to             
          defer payment until December 31, 1994, without paying accrued                
          interest on that deferred amount.  Under paragraph 7 of the                  
          agreement, pertaining to the limited recourse obligations,                   
          Cedilla Invest. was personally liable only for the interest and              
          principal on the note during the times and in the amounts set                
          forth in schedule A.  The amount of recourse obligation as of                
          January 1, 1988, was zero.  The balance of the obligation was                
          nonrecourse, and the payee looked only to the collateral for                 
          payment.                                                                     
               IRA presented no evidence as to which entity had legal title            
          to this equipment under the various agreements.  The purchase                
          agreements of Atlantic indicate that, as a part of each of the               
          lease agreements with Carena, at the end of the lease term, which            
          was either 5, 6, or 6� years, depending on the equipment,                    
          Atlantic would make all efforts to obtain legal title to the                 
          equipment so that it could convey the right, title, and interest             
          in the equipment to the lessee when the end user's lease                     
          terminated.  The price to be paid by Atlantic to obtain the legal            
          title to the equipment was 2 percent of the original value of the            
          equipment.  This indicates that Atlantic had no legal title to               
          pass through the intermediaries to IRA, other than a future                  






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