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The purchase provisions of the IRA/Horizon agreement
included a limited recourse promissory note issued by IRA in
favor of Horizon. This promissory note included deferral
provisions in favor of IRA. The sum could be deferred until
December 31, 1995. Several intermediaries were used. At the
time IRA would receive the equipment, it would have no residual
value.
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.
F. Cedilla Invest.-"Lexet Transactions", "Ben Energy
Transactions", and "Dard Systems Transactions"
These transactions consist of seven (two Lexet, two Ben
Energy, and three Dard Systems) purported purchases and
leasebacks of computer equipment and peripherals manufactured by
IBM, Wang, and others. All of these transactions took place on
December 22, 1986.
The only documents presented by IRA in connection with these
transactions were seven purchase agreements, seven bills of sale,
seven short-term promissory notes, and seven long-term "limited
recourse" promissory notes. No other transactional documents
were produced by IRA, such as equipment appraisals, leases,
economic forecasts, related correspondence, legal opinions, rent
payment schedules, loan payment schedules, checks (negotiated or
otherwise) evidencing payments of purchase price or rents or
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