CMA Consolidated, Inc. & Subsidiaries, Inc. - Page 54

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          lease agreement provided for no actual over lease residual                  
          interests in that equipment.  The over lease agreement set forth            
          a lease term for the K-Mart and Shared equipment that expired on            
          the same dates as the master lease respecting that equipment.7              
               Unlike the ultimate beneficiary in the first lease strip               
          deal, petitioner did not retain its lease position throughout the           
          life of the over lease in the second lease strip deal.  Instead,            
          petitioner disposed of its lease position and/or the associated             
          equipment installment note in three transactions with other                 
          entities over a 21-month period running from November 27, 1995,             
          through September 1, 1997.                                                  
               As to the second lease strip deal, the following complex               
          series of multiparty equipment purchase, lease, and other                   
          transactions took place on August 31, September 1, September 28,            
          and November 27, 1995; and on October 31, 1996, and September 1,            
          1997.                                                                       





               7As discussed supra, the master lease ran:  (1) From Nov. 1,           
          1994, through Oct. 31, 2002, in the case of the K-Mart Corp. (K-            
          Mart) end-user lease equipment, and (2) from Nov. 1, 1994,                  
          through Apr. 30, 2000, in the case of the Shared Medical System             
          Corp. (Shared) end-user lease equipment.  As discussed more fully           
          infra, the Aug. 31, 1995, over lease agreement provided that the            
          over lease ran:  (1) From Aug. 31, 1995, through Oct. 31, 2002,             
          in the case of the K-Mart end-user lease equipment, and (2) from            
          Aug. 31, 1995, through Apr. 30, 2000, in the case of the Shared             
          end-user lease equipment.  Accordingly, petitioner had no                   
          residual lease interests in that equipment.                                 




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