Corbin West Ltd. Partnership, CDC Equity Corp., Tax Matters Partner - Page 2




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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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