Investment Research Associates - Page 477




                                       - 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.                                                      






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