Parker Properties Joint Venture, PDW&A, Inc., A Partner Other Than The Tax Matters Partner - Page 3

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               These cases concern real estate investments of R. James                
          Nicholson (Mr. Nicholson), Philip D. Winn (Mr. Winn), and David             
          A. Gitlitz (Mr. Gitlitz), and several related entities, during              
          the late 1980's.  Empire Savings, Building & Loan Association               
          (Empire), a Colorado savings and loan association, participated             
          directly as the lender of funds to purchase the realty and                  
          indirectly through its wholly owned subsidiary, E.S.L. Corp.                
          (ESL), as an investor in the investing entities.4                           
               Parker Properties and Twenty Mile are partnerships formed,             
          at Empire’s suggestion, for the purposes of acquiring,                      
          developing, and selling the real estate under consideration.                
          Both entities were accrual method taxpayers during the relevant             
          years.                                                                      




          3(...continued)                                                             
          a notice partner of Parker Properties Joint Venture (Parker                 
          Properties) for the year at issue, was filed in docket No. 18386-           
          92.  Sec. 6226(b)(1).  The tax matters partner of Parker                    
          Properties, Nicholson Enterprises, Inc. (Nicholson Enterprises),            
          did not cause a petition for readjustment of partnership items to           
          be filed within the period specified by sec. 6226(a).  However,             
          Nicholson Enterprises timely elected to intervene in docket No.             
          18386-92 in accordance with sec. 6226(b) and Rule 245(a).  PND,             
          Ltd. (PND), is both the notice partner and tax matters partner of           
          Twenty Mile Joint Venture (Twenty Mile) for the year at issue,              
          and its petition was filed in docket No. 18387-92.                          
          4 Empire's equity investment was made based on the                          
          understanding that it was permitted by thrift industry                      
          regulations.  It was also understood that industry regulations              
          required that this type of investment be made through a                     
          subsidiary.                                                                 




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