Spyglass Partners, Richard E. Shea, Tax Matters Partner, et al. - Page 15

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          vein, respondent notes that the amount of capital and loans                 
          contributed by Derrick to each partnership ($10,000 and                     
          $220,000), although placed in escrow, was de minimis when                   
          compared to the purchase price set forth in the agreements.  In             
          other words, respondent contends that both the partnerships and             
          sales agreements were underfunded.                                          
               This lack of funding leads to respondent's additional                  
          contention that the partnerships and sales agreements were                  
          without substance until later documents were drafted and executed           
          and the first installment payments were made.  Respondent accepts           
          that the informal agreements express the parties' intent to agree           
          to buy and sell the condominiums.  However, respondent contends             
          that the sale did not take place in December of 1983.                       
               Finally, respondent suggests that certain language in the              
          December agreements indicates their conditional nature.  For                
          example, respondent refers to the following language:  "In the              
          event Seller or Buyer, as the case may be, elects to terminate              
          the Agreement in accordance with the terms thereof, Seller and              
          Buyer shall cooperate in executing and recording any and all                
          documents necessary to evidence the termination of the                      
          Agreement".  We find that respondent's reliance upon this                   
          language is misplaced.  The referenced language does not                    
          establish that any party could unilaterally escape from its                 
          obligations.                                                                





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