- 5 - ship agreement). During all relevant periods, Partnership, a general partnership governed by the laws of Colorado, maintained its books and records and filed its Forms 1065 on a calendar year basis using the accrual method of accounting. In connection with the formation of Partnership, a series of interrelated events occurred. Contemporaneous with the formation of Partnership, on June 14, 1988, pursuant to a written purchase agreement (purchase agreement), PFI purchased an undivided 35- percent interest in Republic Plaza from BCE, whereupon BCE owned a 65-percent undivided interest therein. Immediately thereafter, also on June 14, 1988, PFI and BCE contributed their respective interests in Republic Plaza to Partnership. Partnership took ownership of Republic Plaza subject to a promissory note, dated April 30, 1986, that obli- gated BCE to pay $200 million to Teachers Insurance and Annuity Association (TIAA). Pursuant to an agreement between TIAA and Partnership that was entered into as of June 14, 1988, that note was restructured. Effective June 17, 1988, as restructured, Partnership became the obligor under the promissory note issued to TIAA (TIAA term loan), the outstanding principal balance of that note was reduced to $177,766,184, the maturity date of that note was changed to May 1, 2011, and that note required monthly payments of varying amounts of principal and interest over the term of the loan until it matured on May 1, 2011.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011