- 6 - 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...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011