Spyglass Partners, Richard E. Shea, Tax Matters Partner, et al. - Page 30

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          over 1 month) the parties' understanding continued to be that the           
          buyers were possessors/owners.  Quitclaim deeds from the buyers             
          to the sellers were held in escrow in order to convey the                   
          condominiums back to the sellers in case of the buyers' defaults.           
          The purpose of the quitclaim deed was to permit the seller to               
          regain unfettered title by eliminating the interest held by the             
          partnerships (i.e. equitable interests).  Accordingly, the buyers           
          (partnerships) had possession, profits, and an equitable interest           
          and had no need to seek specific performance.  Although the                 
          sellers appear to have had the ability to escape if the market              
          value of the condominiums exceeded the contract price, that                 
          aspect was of little import under the circumstances existing at             
          the time the May agreements were executed and until the July 2,             
          1984, closing, just over 1 month later.                                     
               Prior opinions have reached the "option conclusion" mainly             
          because of the relevant amounts at risk or the lack of a                    
          quantitatively relevant remedy.  The factual differences here               
          caused us to reach the ultimate finding that equitable title or             
          the benefits and burdens of ownership of the condominiums resided           
          in the partnerships as of December 1983 and were not divested by            
          the terms of the May agreements.  Under these circumstances, we             
          cannot conclude that the size of the downpayment or liquidated              
          damages should cause a finding that the December agreements were,           
          in effect, options and not contracts for sale.  Further, Utah law           
          does not support an "option finding" with respect to the December           



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