Epic Associates 84-III, William C. Griffith, Jr. - Page 128




                                       - 55 -                                         
             Residential Rental Purchase Agreement dated September 16,                
             1983, between EPIC and U.S. Home.  Furthermore, the                      
             settlement statement for the sale of five of those                       
             properties lists the seller as U.S. Homes.  The record does              
             not contain the settlement statement for the sale of 12103               
             Kingslake Forest Drive.                                                  
                  At trial, respondent introduced warranty deeds that                 
             show that on or about June 1, 1982, the two properties on                
             Heronwood Drive were transferred by U.S. Home to Tanmis                  
             Models, Inc., and on or about August 26, 1983, were                      
             transferred by Tanmis Models, Inc., to EA 84-III.                        
             Respondent also introduced warranty deeds that show that                 
             on or about September 1, 1981, the four properties on                    
             Kingslake Forest Drive were transferred by U.S. Home                     
             to Dyblof Models, Inc., and on or about August 26, 1983,                 
             were transferred by Dyblof Models, Inc., to EA 84-III.                   
                  Apparently, these six properties were models that EPIC              
             acquired from U.S. Home through companies affiliated with                
             EPIC, Tanmis Models, Inc., and Dyblof Models, Inc., and                  
             leased back to U.S. Home.  Under its agreement with EPIC,                
             U.S. Home had the right to buy each property back at the                 
             original purchase price at the end of the lease term.                    
                  EMI assigned to CSL its interest in each of the                     
             promissory notes and related deeds of trust that had been                






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