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Tax Aspects of Private Real Property Syndications
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additional adjusted basis Affiliates allocated alternative minimum tax amendment amount assets attorney Bateman Eichler broker-dealer California California limited capital contributions capital gain cash certiﬁcate of limited Class A Units Code Commission construction Contractor corporation costs court dealer deductions deemed depreciation determined disclosure distribution entitled executed exemption expenses Federal income tax fees ﬁled ﬁling ﬁnancial financing ﬁnder foreign limited partnership Hunt Knight income tax purposes incurred Internal Revenue Service investment investors issuer liability licensed Limited Partners holding limited partnership interest loan loss ment NASD nership offer and sale offeree oﬁering operations ordinary income paid paragraph parties Partners holding Class Partnership Agreement payment percent period person prior Private Placement Memorandum Project public offering purchase price pursuant real estate broker real property recapture received registration statement Regulations risk Rule securities laws sell share speciﬁed subdivision syndication tax consequences thereof tion transaction transfer