Parker Properties Joint Venture, PDW&A, Inc., A Partner Other Than The Tax Matters Partner - Page 10

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               WHEREAS, [ESL] is willing to sell its joint venture                    
               interest in Parker Properties and Twenty Mile for the                  
               sum of $10,000.00 and Commercial is willing to accept                  
               the sum of $10,990,000.00 in full settlement and                       
               satisfaction of its above-described loan balances, all                 
               subject to fulfillment of the terms of this Agreement,                 
               and Parker Properties is desirous of purchasing such                   
               joint venture interests and paying the outstanding                     
               balances of the loans to Commercial as adjusted.                       
          The draft agreement also provided that Parker Properties would              
          pay ESL $10,000 for its interest in Parker Properties and Twenty            
          Mile.  In addition, Parker Properties was to pay Commercial                 
          $7,990,000 cash and deliver a $3 million promissory note.                   
          Handwritten just above the terms of the agreement appeared the              
          following:  "WHEREAS Prior closing Commercial will contribute               
          capital to and reduce indebtedness - ESL wholly owned subs".                
               On June 22, 1988, the investing partners' attorney faxed               
          Commercial and its attorney a followup letter outlining the                 
          transaction and referring to "what the borrower would like the              
          transaction to look like."  The letter contained the following              
          chart which detailed "how the transaction would result":                    
                                   Convert to                                         
                         Debt       Equity   Forgive   To be Paid Note                
          Parker Properties $9,319,963   $3,419,963   ---       $2,900,000  $3,000,000
          Twenty Mile        3,395,492    1,395,492   ---2,000,000    ---               
          Parker 480         3,256,910       ---   $156,9103,100,000     ---             
          Total     15,972,365    4,815,455  156,910     8,000,000   3,000,000        
               On June 28, 1988, Commercial’s accountant was asked to                 
          provide his comments "from a tax standpoint."  Based on his                 
          understanding of the proposed agreement, the accountant opined              
          that:                                                                       





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