Epic Associates 84-III, William C. Griffith, Jr. - Page 77




                                       - 160 -                                        
             upon the perceived success of the limited partnerships that              
             it syndicated.  As a result, EPIC advanced a high                        
             percentage of the lump-sum payments and fees that it                     
             realized from the acquisition of new properties to satisfy               
             the obligations of older partnerships, and thus to make                  
             sure that none of the partnerships defaulted on its                      
             obligations.  In choosing to make those advances and                     
             prevent any default, the management of EPIC continued to                 
             believe that it could carry the properties until interest                
             rates decreased and the real estate market turned around.                
             Respondent also ignores the fact that EPIC was entitled to               
             25 percent of the net profits from the sale of properties,               
             so-called back-end appreciation.  Mr. Clayton McQuistion,                
             an important member of EPIC's management, referred to this               
             as "a gigantic profit opportunity".                                      
                  Based upon the record of these cases, we find that                  
             EPIC, acting as the general partner of both EA 83-XII and                
             EA 84-III, engaged in the activities of both partnerships                
             with an actual and honest objective of making a profit.                  

             EPIC's Advances to EA 83-XII and EA 84-III                               
                  As mentioned above, respondent determined in the                    
             subject notices of FPAA that the deductions for interest                 
             claimed by each partnership with respect to the unsecured                







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