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1. Whether Library Square may deduct depreciation it
claimed for the cost of obtaining development rights for 1989
through 1996. We hold that it may to the extent discussed below.
2. Whether Fifth & Grand may deduct depreciation it
claimed for the cost of obtaining development rights for 1991,
1992, 1994, 1995, and 1996. We hold that it may to the extent
discussed below.
References to petitioners are to petitioner Maguire/Thomas
Partners, Hope Place, Ltd. (Hope Place), the tax matters partner
of Library Square, and petitioner Maguire/Thomas Partners Grand
Place Tower, Ltd. (Grand Place), the tax matters partner of Fifth
& Grand. Section references are to the Internal Revenue Code in
effect for the years in issue, unless stated otherwise. Rule
references are to the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners and Their Limited Partnerships
1. Petitioners
When the petitions were filed, the principal place of
business for each partnership and its tax matters partner was Los
Angeles, California.
2. The Limited Partnerships
Library Square and Fifth & Grand are limited partnerships
organized under California law. Library Square operates Library
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