L&C Springs Associates, Solomon A. Weisgal Investment Associates, Tax Matters Partner, et al. - Page 22

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            and the other entities involved in this transaction had for all                           
            intents and purposes (apart from L&C Springs' reporting of the                            
            income in question for 1991) treated L&C Springs as having no                             
            continuing substantive ownership interest in the L&C Properties.                          
            Effectively, as of November 1, 1990, L&C Springs' ownership                               
            interest in the L&C Properties was not regarded as viable by the                          
            parties, had no value, and was effectively extinguished.                                  
                  The October 1990 Agreement between Tanglewood and Cal Fed                           
            transferred all attributes of ownership (except nominal title) of                         
            the L&C Properties from Tanglewood to Cal Fed.  It effectively                            
            relieved L&C Springs of its $2,250,000 debt obligation to                                 
            Tanglewood and disposed of L&C Springs' leasehold interest in the                         
            L&C Properties.                                                                           
                  Neither in 1987, 1988, 1989, 1990, nor in any later year,                           
            did Tanglewood seek to collect the defaulted $2,250,000 debt                              
            obligation due from L&C Springs.  Tanglewood's financial                                  
            disclosures in its bankruptcy proceeding in 1990 did not disclose                         
            L&C Springs’ stated debt obligation to Tanglewood as an asset of                          
            Tanglewood.                                                                               
                  The credible evidence indicates that L&C Springs' tax return                        
            treatment of the termination of its ownership interest in the L&C                         
            Properties as not having occurred until 1991 constituted simply                           
            an attempt, by the various individuals associated with L&C                                
            Springs and Tanglewood, to defer, for income tax purposes,                                






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