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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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