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Los Angeles determined that many old buildings, including
petitioner’s building, required retrofitting to bring them up to
prescribed earthquake safety standards, and petitioner was issued
a notice requiring him to retrofit his building. If petitioner
failed to retrofit his building, the city ultimately would close
the building and demolish it.
In planning and carrying out the earthquake retrofitting and
refurbishing work on the building, petitioner acted as his own
general contractor. He hired architects and civil and structural
engineers and prepared a plan for the work required. He applied
to the city of Los Angeles for plan approval. Beginning in 1987,
petitioner also entered into contracts with various engineers and
contractors in connection with the building’s renovation and
improvement.
On or about July 2, 1987, petitioners received a $213,700
Small Business Administration program loan to retrofit and
refurbish the building (the SBA loan).
From September 1980 through early July 1987, petitioner had
continued to rent space on the first floor of the building to
various tenants. Shortly after petitioner received the SBA loan,
petitioner’s tenants vacated the premises to allow the earthquake
retrofitting work on the building to proceed. From about July
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