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Petitioner is a unitholder of the Roscrea Trust that
was formed by 24 partners and principals of a major
national accounting firm specifically to facilitate their
participation in the subject sale-leaseback transaction.
Pursuant to a Purchase, Sale and Assignment Agreement dated
December 28, 1982 (Sale Agreement), the Trust purchased an
interest in certain computer equipment from Systems
Leasing, Inc. (Systems). The Sale Agreement describes the
equipment as Domestic Equipment and Foreign Equipment. The
Domestic Equipment consisted of equipment manufactured by
IBM and leased to Burroughs Wellcome Co., the initial user,
for a 60-month term beginning on or about June 1, 1982, and
equipment manufactured by Control Data Corp. and leased to
First Computer Corp., the initial user, for a 37-month term
beginning on or about August 31, 1982. The Foreign Equip-
ment was manufactured by IBM and was leased to DuPont de
Nemours (Deutschland) GmbH, the initial user, part of
it for a 48-month term beginning on or about November 1,
1982, and part of it for a 36-month term beginning on or
about the same date.
At the time the Trust entered into the Sale Agreement,
the equipment was subject to two master leases, one cover-
ing the Domestic Equipment between Systems and Equilease
Associates I Limited Partnership, and one covering the
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