- 524 - In view of the foregoing, all deductions and credits associated with this transaction and claimed by IRA on its Federal income tax returns are disallowed. D. IRA-1980 Domestic Transaction (Mini Computer Transaction) This transaction involved a purported sale of miscellaneous equipment by FSAM to F/S, an entity affiliated with FSC, to Horizon, and then from Horizon to IRA. Payment of $870,025 by IRA was made primarily with a limited recourse promissory note in the amount of $864,325. The amounts for the payments from IRA to Horizon were equal to the amounts of the payments owed under the lease agreement. An agreement was reached between IRA, FSAM, and Horizon that these payments were to offset each other, so only bookkeeping entries were made. The interests of IRA in and to the computer equipment were subject to the interests of prior lienholders and the underlying lessee. The leases were assigned to IRA through the use of a collateral assignment by F/S. The promissory note included a deferral provision allowing IRA to defer payments on the note, until December 31, 1995, without any interest accruing on the deferred amount if, and to the extent, amounts of rent were not paid to IRA. The equipment could be replaced. The recourse obligation under those provisions in the note provided that Horizon had recourse against IRA as of January 1, 1989, in the amount of zero dollars.Page: Previous 514 515 516 517 518 519 520 521 522 523 524 525 526 527 528 529 530 531 532 533 Next
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