- 71 -
1983 1984 1985
Total interest expense reported$118,082 $522,466 $545,848
Interest on first mortgage notes1123,029 492,116 492,116
Difference (4,947) 30,350 53,732
1 Four months of interest.
The record of this case does not fully explain the above
differences.
EA 84-III paid loan origination fees to EMI in the
aggregate amount of $138,138 equal to 4 percent of the
principal amount of the first mortgage loans (i.e.,
$3,453,450 x 4 percent). On the subject returns,
EA 84-III claimed a deduction for "amount of points"
of $3,453, $13,814, and $13,814, respectively.
EPIC
As mentioned above, EPIC, the general partner of
EA 83-XII and EA 84-III, was incorporated in 1974 for
the purpose of acquiring residential real properties
and providing various services in connection with the
acquisition, syndication, management, and disposition
of the properties. Between 1975 and 1985, EPIC formed
approximately 357 limited partnerships with more than 6,000
limited partners. EPIC was the general partner of each
limited partnership. These partnerships owned
approximately 17,600 residential dwelling units located
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