L&C Springs Associates, Solomon A. Weisgal Investment Associates, Tax Matters Partner, et al. - Page 25

                                               - 25 -                                                 
            Properties and the underlying land, and Cal Fed received the                              
            benefits of ownership.  As of November 1, 1990, no additional                             
            funding was available, and the individuals involved with                                  
            Tanglewood and L&C Springs knew that no further funds would                               
            become available and agreed that a foreclosure sale would occur                           
            and that no right of redemption was available.  Only formal,                              
            nominal title to the property was withheld from Cal Fed until                             
            1991.  By November 1, 1990, L&C Springs had effectively abandoned                         
            its leasehold interest in the L&C Properties and the related                              
            land, and L&C Springs was relieved by such abandonment of its                             
            nonrecourse debt obligation to Tanglewood.                                                
                  Based on the above analysis, L&C Springs is required to                             
            realize, as of November 1, 1990, income associated with the                               
            termination of its interest in the L&C Properties and with the                            
            relief from its $2,250,000 debt obligation to Tanglewood on the                           
            L&C Note.  Also, any interest expense deductions and depreciation                         
            deductions claimed by L&C Springs for periods of time after                               
            October 31, 1990, are to be disallowed.5                                                  

                                                Decisions will be entered                             
                                                under Rule 155.                                       

            5     Petitioners’ counsel represent that L&C Springs should have                         
            a limited right under mitigation to open up L&C Springs’ 1991                             
            taxable year to remove the gain reported for 1991 relating to the                         
            transaction that we treat herein as taxable in 1990.  Our opinion                         
            herein, however, is not dependent upon correction of petitioners’                         
            treatment of this item for 1991.                                                          





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