Francine Acquaviva - Page 9

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               During 1985, the Monmouth County Board of Freeholders was              
          considering the purchase and conversion of 457 acres of farmland            
          into a public park, 366 acres of which was owned by HGCC.  In               
          July 1986, Monmouth County filed a declaration of taking against            
          279 acres of land owned by HGCC and deposited $14,524,600, the              
          property's estimated fair market value, with the Superior Court             
          of New Jersey.  The condemnation proceedings, including the                 
          amount of the condemnation award, were reported in local                    
          newspapers; petitioner read some of these articles and attended a           
          few of the public hearings concerning the condemnation.                     
               Mr. Acquaviva consulted his accountant, Louis Defalco (Mr.             
          Defalco), regarding the tax implications of the condemnation                
          award.  Mr. Acquaviva and Mr. DiMisa were advised by Mr. Defalco            
          that they had the option of replacing the property and deferring            
          the recognition of any gain or of recognizing the gain currently.           
          Mr. DiMisa also suggested that Mr. Acquaviva and he discuss the             
          matter with Herbert Gannette (Mr. Gannette), a tax attorney.  In            
          the interim, HGCC reported a gain in the amount of $7,678,378               
          from the condemnation on its 1986 Form 1065, U.S. Partnership               
          Return of Income.  HGCC issued checks to each partner for                   
          $3,869,244, which represented each partner's share of the                   
          proceeds from the condemnation award after deduction of expenses.           
          Mr. Acquaviva deposited his share into his personal checking                
          account.  However, HGCC subsequently filed an amended Form 1065,            
          electing to defer this gain pursuant to section 1033.                       




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