- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011