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collectively as the 3UBC Transaction.
b. Tax Treatment of the 3UBC Transaction
On its Federal income tax return filed for 1988, the UBC
affiliated group reported gain on the installment basis using an
amount realized of $14,201,933 from the sale of 3UBC. The
parties agree that the reported amount is the correct amount
realized for purposes of determining gain or loss from the sale
of 3UBC.
On its Federal income tax return filed for 1988, the UBC
affiliated group reported gain on the installment basis using an
adjusted basis of $5,321,361 for purposes of determining gain or
loss on the sale of 3UBC. The parties agree that the reported
adjusted basis is correct, except to the extent, if any, that the
cost of the Atrium Assets, see supra sec. II.A.7., is allocable
to the basis of 3UBC.
10. The 1UBC Land Transaction
By a purchase and sale agreement dated December 30, 1988,
LBC sold the 1UBC land (together with LBC's interest in the
Ground Lease relating to the 1UBC land) to ARICO (the 1UBC land
transaction). LBC realized $2,900,000 as a result of that
transaction. On its Federal income tax return filed for 1988,
the UBC affiliated group reported the sale of the 1UBC land as a
long-term capital loss using an adjusted basis of $2,953,980.
The parties agree that the reported adjusted basis is correct,
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