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 10

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          the equipment), thereby reducing Comdisco’s alternative minimum             
               Between 1993 and 1996, Comdisco had a wholly owned subsidiary,         
          Comdisco Investment Group, Inc. (CIG).  CIG’s executives included:          
          Frank Trznadel-–president; Robert Snyder--executive vice president;         
          and Paula Ortmann–vice president.                                           
               CIG assisted Comdisco in structuring sale-leaseback                    
          transactions of computers involving foreign investors and U.S.              
          corporations (domestic corporations), referred to by Comdisco as            
          cross-border equipment leasing transactions.  CIG presented to              
          domestic corporations proposals for cross-border equipment leasing          
          transactions between Comdisco, partnerships made up of the foreign          
          investors, and the domestic corporations.2  The proposals stated in         
          relevant part:                                                              
                         COMDISCO EQUIPMENT LEASING CONCEPT                           
                    Comdisco has developed a cross-border equipment                   
               leasing transaction that produces permanent U.S. tax                   
               savings through the advantageous use of U.S. tax rules                 
               concerning the acceleration of taxable income from rents.              
                    Unlike most Western countries, the United States                  
               treats as taxable income any amounts received as prepaid               
               rent or as proceeds from a sale, without recourse, of a                
               stream of rental payments.  These amounts are income even              
               though they are unearned and are attributable to future                

               2    Comdisco had entered into transactions similar to the             
          transaction at issue in these cases.  Prior transactions involved           
          the participation of the following four partnerships:  Fillupar             
          Leasing (1991); Astropar Leasing (1991); Compupar Leasing (I)               
          (1992); and Compupar Leasing (II) (1992).                                   

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