L&C Springs Associates, Solomon A. Weisgal Investment Associates, Tax Matters Partner, et al. - Page 3

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            Springs' interest in the L&C Properties should be treated as                              
            having been terminated in 1988 or 1989.                                                   
                  The only issue for decision is whether L&C Springs’                                 
            ownership interest in the L&C Properties was abandoned or                                 
            terminated triggering for Federal income tax purposes a sale or                           
            exchange of L&C Springs' interest therein in 1988, 1989, or 1990.                         
            If we conclude that L&C Springs’ ownership interest in the L&C                            
            Properties was abandoned or terminated in one of those years,                             
            then L&C Springs would be required, under sections 1001, 1231,                            
            1245, and 1250, to recognize ordinary income and capital gain in                          
            the year of such abandonment or termination based on the amount                           
            of accelerated depreciation claimed on the L&C Properties and on                          
            the amount realized on such sale or exchange.  Also, the above                            
            interest and depreciation deductions that were claimed for 1988,                          
            1989, and 1990 with respect to L&C Springs' ownership interest in                         
            the L&C Properties would not be allowable for any period of time                          
            after such abandonment or termination occurred.                                           

                                         FINDINGS OF FACT                                             
                  On May 5 and June 30, 1980, Tanglewood Properties, Inc.                             
            (Tanglewood), purchased from the Clinton Family Trust for a total                         
            stated consideration of $2.1 million, subject to three existing                           
            mortgages securing the land and buildings, an ownership interest                          
            in a Florida land trust that owned the L&C Properties and the                             
            related land.  The L&C Properties were located in Miami and in                            





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