- 5 - 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 thePage: 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