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The issues for our decision are: (1) Whether a note
executed by Corbin West should be included in the basis of
certain acquired property for purposes of computing depreciation
deductions and low-income housing credits, (2) whether Corbin
West is entitled to interest deductions for the accrued interest
on that note, (3) whether Corbin West is entitled to include an
"acquisition fee", a "developer's fee", or a "tax credit
guarantee fee" in the basis of certain acquired property or,
alternatively, whether Corbin West may currently deduct any of
those fees, and (4) whether Corbin West is entitled to
amortization expense for a "no negative cash flow guarantee fee"
paid.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference.
Corbin West is a TEFRA partnership. At the time of the
filing of the petition, its principal place of business was
located in Farmington, Connecticut. Corbin West consists of one
general partner, CDC Equity Corp. (CDC), and 29 limited partners.
CDC is the wholly owned subsidiary of CDC Financial Corp.
(Financial).
CDC is the tax matters partner of Corbin West. Pursuant to
Rule 240(c), CDC filed a petition requesting a redetermination of
respondent's adjustments to partnership items.
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Last modified: May 25, 2011