- 3 - 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 LibraryPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011