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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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