2925 Briarpark, Ltd., James C. Motley, Tax Matters Partner - Page 3

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          James C. Motley                         General partner                     
          David D. Livingston, as trustee         Limited partner                     

          James C. Motley (Mr. Motley) was a general partner and the tax              
          matters partner of Briarpark.                                               
               During 1983 and 1984, Briarpark acquired a 3-acre parcel of            
          land at 2925 Briarpark Road (property) and constructed a 12-story           
          office building on the property.  Around September 27, 1983,                
          Briarpark borrowed $21,600,000 from InterFirst Bank Houston                 
          (InterFirst) to finance the acquisition of the property and the             
          construction of the building (original loan).  Mr. Motley                   
          executed a guaranty for principal, interest, penalties, expenses,           
          and fees due on the original loan.                                          
               On May 28, 1987, Briarpark and InterFirst modified and                 
          extended the original loan (modified loan) pursuant to a modified           
          loan agreement.  Under the agreement, Mr. Motley's obligation               
          under the guaranty was limited to $5 million, the original loan             
          was converted from recourse to nonrecourse, and the accrued but             
          unpaid interest in the amount of $3,100,000 was capitalized.  At            
          that time, InterFirst estimated that the fair market value of the           
          property was approximately $17 million.  Also on May 28, 1987,              
          Briarpark obtained a loan in the amount of $1,500,000 for tenant            
          improvements (build-out loan) on a nonrecourse basis.                       
               On April 15, 1988, Briarpark filed its U.S. Partnership                
          Return, Form 1065, for taxable year 1987.  Briarpark did not                
          report any income on its 1987 return with respect to the original           




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