Norwest Corporation and Subsidiaries, Successor in Interest to United Banks of Colorado, Inc., and Subsidiaries, et al. - Page 26

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                         Cost Bases                                                   
          Taxable                                           Atrium                    
          Year Placed    Atrium              Atrium         Security System           
          in Service       Structure  Skyway       Cafe       and Signage             
          1986      $31,805,978 --  --  --                                            
          1987           --          $26,195    $1,676,090  $246,453                  
          1989           --             --           2,058  699                       
          1990      144,261             --          21,917  10,800                    
               On its Federal income tax returns for the taxable years 1986           
          through 1991, the UBC affiliated group claimed depreciation                 
          deductions with respect to the Atrium Assets as follows:                    
                         Depreciation Claimed                                         
                                                           Atrium                    
          Taxable        Atrium              Atrium         Security System           
          Year          Structure     Skyway       Cafe       and Signage             
          1986         $234,121 --  --  --                                            
          1987           2,458,735      $2,009      $134,960--                        
          1988           2,104,223         938       266,895$60,381                   
          1989           1,190,409         930       190,19043,211                    
          1990           1,191,171         930       148,15131,505                    
          1991           344,402         295        39,458  8,955                     
          The depreciation deductions claimed on the Atrium Assets were               
          computed on 100 percent of the cost bases of the assets as set              
          forth above, except that, after 1988, the depreciation deductions           
          claimed with respect to the Skyway and that portion of the Atrium           
          Structure placed in service prior to 1989 were computed on                  
          51.5152 percent of the assets' cost bases.                                  
                    8.  The 2UBC Transaction                                          
                    a.  The Various Agreements                                        
               Den-Cal Co. (Den-Cal) was a California limited partnership             
          whose managing general partner was Emerik Properties Corp.                  
          (Emerik).                                                                   
               By a purchase and sale agreement dated July 16, 1985, LBC              
          sold 2UBC and the land thereunder and an undivided 50-percent               



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