L&C Springs Associates, Solomon A. Weisgal Investment Associates, Tax Matters Partner, et al. - Page 2

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            adjustments to L&C Springs Associates’ (L&C Springs’) 1988, 1989,                         
            and 1990 Federal partnership income tax returns, as follows:                              

                           Respondent's Partnership Adjustments                                       
                           Income On Discharge        Interest        Depreciation                    
                  Year     Of Indebtedness            Expense         Expense                         
                  1988         $2,250,000             $(254,413)      $(168,350)                      
                  1989         2,250,000               (264,858)        (167,707)                     
                  1990         2,250,000               (261,961)        (167,722)                     

                  Unless otherwise indicated, all section references are to                           
            the Internal Revenue Code in effect for the years in issue, and                           
            all Rule references are to the Tax Court Rules of Practice and                            
            Procedure.                                                                                
                  The above $2,250,000 in income that respondent charged to                           
            L&C Springs in respondent's FPAA for each of the years 1988,                              
            1989, and 1990 is the same item of income and relates to                                  
            respondent's contention that L&C Springs' ownership interest in                           
            two apartment complexes (the L&C Properties) through a Florida                            
            land trust was effectively abandoned or terminated in either                              
            1988, 1989, or 1990, triggering, for Federal income tax purposes,                         
            a sale or exchange of L&C Springs' interest in the L&C                                    
            Properties.                                                                               
                  Respondent's primary position is that L&C Springs' ownership                        
            interest in the L&C Properties should be treated as having been                           
            terminated as of the end of October of 1990.  Alternatively and                           
            only as a protective measure, respondent contends that L&C                                






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