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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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