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deal, the Iowa Tribe had the same role, involvement, and
participation in Kanawha as the Iowa Tribe had in CFP for
purposes of the first lease strip deal.
2. On August 31, 1995, CAP transferred ownership of the K-
Mart and Shared end-user lease equipment, along with the right to
receive master lease rental payments upon that equipment, to
Jenrich Corp. (Jenrich) in exchange for two notes.8 One Jenrich
note was a $4,056,220 long-term nonrecourse secured installment
note with 8 percent interest payable in:
(i) thirteen (13) semi-annual installments of principal
and interest, each in the amount of $371,301 payable on
February 28th and August 30th of each year, commencing
on February 28, 1996 through and including February 28,
2002, and (ii) four (4) semi-annual installments of
principal and interest, each in the amount of $159,876
payable on August 30th and February 28th of each year,
commencing August 30, 2002, through and including
February 28, 2004.
The other Jenrich note was a $215,000 short-term note due
November 29, 1995. Both notes were signed by Marlene Freedman
(Freedman), Jenrich’s sole shareholder and president.
8For its taxable years ended Mar. 31, 1995 and 1996, Jenrich
Corp. (Jenrich) claimed losses of $4,879,471 and $16,203,523,
respectively. From its 1995 through 1997 fiscal years, Jenrich’s
deficit in retained earnings for financial accounting purposes
also increased dramatically: For its year ended Mar. 31, 1995,
Jenrich’s deficit in retained earnings increased from $24,806 to
$137,303,245; for its year ended Mar. 31, 1996, Jenrich’s deficit
in retained earnings increased from $137,303,245 to $153,506,768;
and for its year ended Mar. 31, 1997, Jenrich’s deficit in
retained earnings increased from $153,506,768 to $155,502,577.
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