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2. The Contractor shall review all documents relating
to the series of transactions described above to
determine:
(1) exactly what rights were purchased;
(2) whether these rights remain even after the
life of the building has expired; and
(3) the useful life of these rights
3. The Contractor shall convey the results of its
review, research and analysis in a written narrative
appraisal report, with adequate supporting
documentation to enable the reader to follow the
thought process throughout the entire report, and
arrive at the logical conclusion.
OPTIONAL LINE ITEM:
4. At the option of the Government, the Contractor may
be required to provide up to (8) hours of consultation
time and travel to the Los Angeles area to attend a
closing conference with IRS personnel and taxpayer
representatives to discuss the findings. At this
conference, the Contractor shall interface with
taxpayer experts in discussing this issue.
5. At the option of the Government, the Contractor may
be contacted to provide any appropriate pre-trial
preparation and trial testimony in U.S. Tax Court.
Mr. Harkavy made a Contract Proposal with respect to the
request for bids, which added the following services to those set
forth in the request for bids:
4. Research underlying Code Sections, Regulations and
Court Cases. Research should initially concentrate on
the threshold questions of whether air rights, FARs,
and TDRs are solely allocable to land, and therefore
not depreciable, or alternatively, an allocation should
be made between land and improvements. If an
allocation is required, the criteria for this
allocation must be established.
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Last modified: May 25, 2011