Republic Plaza Properties Partnership, PFI Republic Limited, Inc., Tax Matters Partner - Page 9

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          that start on June 1 and end on May 31, the total amount of basic           
          rent to be paid by BCE was as follows:5                                     
               Total Amount of                                                        
               Annual Lease Period                    Basic Rental Payments           
               June 1, 1989, through May 31, 1990      $27,185,083.85                 
               June 1, 1990, through May 31, 1991      27,185,083.85                  
               June 1, 1991, through May 31, 1992      27,185,083.85                  
               June 1, 1992, through May 31, 1993      27,185,083.85                  
               June 1, 1993, through May 31, 1994      27,185,083.85                  
               June 1, 1994, through May 31, 1995      27,185,083.85                  
               June 1, 1995, through May 31, 1996      27,185,083.85                  
               June 1, 1996, through May 31, 1997      27,185,083.85                  
               June 1, 1997, through May 31, 1998      27,185,083.85                  
               June 1, 1998, through May 31, 1999      27,185,083.85                  
               June 1, 1999, through May 31, 2000      27,185,083.85                  
               June 1, 2000, through May 31, 2001      33,226,213.70                  
               June 1, 2001, through May 31, 2002      33,226,213.70                  
               June 1, 2002, through May 31, 2003      33,226,213.70                  
               June 1, 2003, through May 31, 2004      33,226,213.70                  
               June 1, 2004, through May 31, 2005      33,226,213.70                  
               June 1, 2005, through May 31, 2006      33,226,213.70                  
               June 1, 2006, through May 31, 2007      33,226,213.70                  
               June 1, 2007, through May 31, 2008      33,226,213.70                  
               June 1, 2008, through May 31, 2009      33,226,213.70                  
               June 1, 2009, through May 31, 2010      33,226,213.70                  
               June 1, 2010, through May 31, 2011      33,226,213.70                  
               June 1, 2011, through May 31, 2012      33,226,213.70                  
               June 1, 2012, through May 31, 2013      27,185,083.85                  
               For each of the 22-annual lease periods immediately follow-            
          ing the 11.5-month period of zero rent, the rent payment schedule           


          5  One of petitioner's exhibits that purported to show that the             
          rent payment schedule complied with the standards established by            
          Rev. Proc. 75-21, 1975-1 C.B. 715, indicated that the total                 
          amount of basic rent to be paid for each of the 24-annual lease             
          periods following the 11.5-month period of zero rent was slightly           
          greater than the total amount of basic rent to be paid for each             
          such period that we have calculated in accordance with Schedule             
          E.  Although it is unclear from the record why these minimal                
          discrepancies exist, they do not affect our findings or conclu-             
          sions herein.                                                               




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