- 20 - 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.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011