- 22 - 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,Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011