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grantor trusts.2 The initial trustee (trustee) of each of the
six grantor trusts was The Connecticut Bank and Trust Company,
National Association (Connecticut Bank). Thereafter, State
Street Bank & Trust Company succeeded Connecticut Bank as the
trustee of each of such grantor trusts.
The trustee of each grantor trust entered into various
interrelated and interdependent agreements with petitioner, each
of which was dated as of November 1, 1985. (We shall refer to
all the various interrelated and interdependent agreements that
petitioner and the trustee of each grantor trust entered into as
the 1985 sale and leaseback or the 1985 sale and leaseback
agreement.3) Pursuant to all six of the 1985 sale and leaseback
2The initial six owner participants and the respective
percentage undivided ownership interests in the AVS unit II that
they acquired from petitioner were:
Owner Participant Percentage Undivided Interest
First Chicago Leasing Corporation 4.3334
Dart & Kraft Financial 36.8333
Corporation
Beatrice Financial Services, Inc. 10.8333
J.C. Penney Company, Inc. 30.6667
Saks & Company 9.0000
Chrysler Financial Corporation 8.3333
3Although the trustee of each of the grantor trusts was a
party to each 1985 sale and leaseback agreement, each owner
participant was the real party in interest to such agreement.
Unless otherwise indicated, we shall for convenience when dis-
cussing the 1985 sale and leaseback agreement(s) refer to the
owner participant(s) and not to the trustee.
(continued...)
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