Republic Plaza Properties Partnership, PFI Republic Limited, Inc., Tax Matters Partner - Page 2

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          (Partnership), for an award under section 7430 of reasonable                
          litigation costs (PFI's motion).  Neither party has requested a             
          hearing, and we conclude that one is not necessary.  Rule                   
          232(a)(3).  Based on the submissions of PFI and respondent, we              
          conclude that no litigation costs may be awarded under section              
               Respondent determined in the notice of final partnership               
          administrative adjustment (FPAA) adjustments to the Form 1065               
          (Federal partnership return) that Partnership filed for 1988 that           
          related to certain depreciation claimed and to the lease (lease             
          agreement) of an office building between Partnership as lessor              
          and BCE Development Properties, Inc. (BCE) as lessee.  The                  
          petition in this case that was filed on December 16, 1994,                  
          contested those adjustments, the parties settled the depreciation           
          adjustments, and the Court issued an Opinion on the adjustments             
          relating to the lease agreement in Republic Plaza Properties                
          Partnership v. Commissioner, 107 T.C. 94 (1996) (Opinion).  We              
          incorporate herein by reference the portions of our Opinion that            
          are relevant to our disposition of PFI's motion.                            
               On June 14, 1988, PFI purchased from BCE an undivided 35-              
          percent interest in Partnership.  On February 28, 1992, PFI                 
          transferred that interest to Brookfield Development.  However,              
          PFI retained all financial interest and/or tax liability with               
          respect to Partnership's 1988 and 1989 Federal partnership                  

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