Ronald and Barbara Kimmich - Page 3




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                                  FINDINGS OF FACT                                    
               The parties submitted the instant case fully stipulated.               
          The parties' stipulation of facts is incorporated herein by                 
          reference and these stipulated facts are found as facts in the              
          instant case.  Petitioners resided in Gibsonia, Pennsylvania,               
          when they filed their petition.                                             
               During the years in issue, Elmco Inc. (Elmco) was a Maryland           
          corporation offering equipment leasing transactions to investors.           
          Greyhound Capital Corp. (GCC), a New York corporation, was in the           
          business of leasing and marketing computers and related                     
          equipment.  On December 22, 1982, Elmco purchased computer                  
          equipment from GCC that it later sold to petitioner.  A                     
          promissory note, dated December 22, 1982, required Elmco to first           
          pay GCC $830 per month for 36 months, then $11,716.70 per month             
          for 72 months.2  All monthly payments accrued in arrears and were           
          paid quarterly on the first day of April, July, October, and                
          January.  Additionally, on December 31, 1982, Elmco was required            
          to pay GCC $1,240.71, which payment constituted interest through            
          December 31, 1982.                                                          
               Also, on December 22, 1982, petitioner entered into a                  
          "Purchase Agreement" with Elmco to purchase the same computer               




          2    Neither party introduced evidence of the recourse or                   
          nonrecourse nature of this note.                                            




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