Lowell L. and Marilyn A. Robertson - Page 5




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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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