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Torrey Hotel Enterprises, Inc. (THEI), the tax matters partner
of IHCL and petitioner in this case, is a California corporation.
All of the outstanding shares of stock of THEI were directly or
indirectly owned or controlled by Mr. Manchester or members of his
family.
Douglas F. Manchester, PLH, and PGL
In October 1981, Mr. Manchester and his related companies
formed Pacific Landmark Hotel, Ltd. (PLH), a California limited
partnership. PLH was formed for the purpose of constructing,
owning, and managing the first of two hotel towers of a resort
complex located adjacent to the then-unbuilt San Diego Convention
Center. The first hotel tower was completed in April 1984.
Mr. Manchester formed another limited partnership, Pacific
Gateway, Ltd. (PGL), for the purpose of constructing, owning, and
managing the second hotel tower. In October 1985, PGL commenced
construction of the second hotel tower; it was completed in October
1987.
IHCL and THEI
Mr. Manchester formed IHCL to hold interests in PLH and PGL.
Under the Agreement of Limited Partnership of IHCL, dated October
3, 1985 (the IHCL Original Agreement), the general and tax matters
partner of IHCL was THEI, which had a .999-percent interest in IHCL
as a general partner and a 99-percent interest as a limited
partner. Mr. Manchester held the remaining .001-percent interest.
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