Maguire/Thomas Partners Fifth & Grand, Ltd., Maguire/Thomas Partners Grand Place Tower, Ltd., Tax Matters Partner - Page 3

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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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