Andantech L.L.C., Wells Fargo Equipment Finance, Inc. (f.k.a. Norwest Equipment Finance, Inc.), Tax Matters Partner, and Wells Fargo & Co., A Partner Other Than the Tax Matters Partner, et al. - Page 1


                                  T.C. Memo 2002-97                                   

                               UNITED STATES TAX COURT                                

           ANDANTECH L.L.C., WELLS FARGO EQUIPMENT FINANCE, INC. (f.k.a.              
            FARGO & COMPANY (f.k.a. NORWEST CORPORATION), A PARTNER OTHER             
                THAN THE TAX MATTERS PARTNER, ET AL.,1 Petitioners v.                 
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 15532-98, 4277-00,     Filed April 9, 2002.                

                    On Sept. 28, 1993, A, a limited liability Wyoming                 
               company, composed of two Belgian citizens, BP and FBE,                 
               purchased a portfolio of 40 IBM mainframe computers (the               
               equipment) from C, for $122,415,762, which was paid:  (1)              
               $14,995,931 in cash (which A borrowed from UBS, a Swiss                
               bank), and (2) $107,419,831 by A’s notes to C.  At the                 
               time of sale, the equipment was under existing leases to               
               end users and subject to existing liens; the equipment                 
               was sold to A subject to the existing leases and liens.                
                    Simultaneously with its purchase of the equipment,                
               A leased the equipment back to C.                                      

               1    Cases of the following petitioners are consolidated               
          herewith:  Andantech L.L.C., Equipment Investors Co., Inc., A               
          Partner Other Than The Tax Matters Partner, docket Nos. 4277-00             
          and 6348-00.                                                                

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