Republic Plaza Props. Pshp. v. Commissioner

107 T.C. No. 7, 107 T.C. 94, 1996 U.S. Tax Ct. LEXIS 38
CourtUnited States Tax Court
DecidedSeptember 16, 1996
DocketDocket No. 23300-94.
StatusPublished
Cited by39 cases

This text of 107 T.C. No. 7 (Republic Plaza Props. Pshp. v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Republic Plaza Props. Pshp. v. Commissioner, 107 T.C. No. 7, 107 T.C. 94, 1996 U.S. Tax Ct. LEXIS 38 (tax 1996).

Opinion

Chiechi, Judge:

In the notice of final partnership administrative adjustment (fpaa), respondent determined adjustments to the Form 1065 (Federal partnership return) that Republic Plaza Properties Partnership (partnership) filed for 1988.

The issues remaining for decision are:

(1) Is the 11.5-month period of zero rent at the beginning of the lease (lease agreement) of an office building by partnership to BCE Development Properties, Inc. (bce), a reasonable rent holiday described in section 467(b)(5)(C)? We hold that it is;

(2) did the lease agreement provide that the amount of a letter of credit (viz, $8,872,245), which at the request of BCE was issued in favor of partnership, is rent that is allocated to the first 11.5 months of that agreement so that partnership is required for 1988 to accrue as rent the amount of that letter of credit? We hold that the lease agreement does not so provide and that partnership is not required to accrue that amount as rent for 1988.

FINDINGS OF FACT

Some of the facts have been stipulated and are so found. PFI Republic Limited, Inc. (pfi), is the tax matters partner for partnership. At the time the petition was filed, partnership’s principal place of business was in Portland, Oregon.

In 1987, Commercial Union Capital Corp. (Commercial Union), an investment banker employed by BCE, approached PFI concerning pfi’s interest in investing in a sale-leaseback transaction involving a 56-story office building located in the central business district of Denver, Colorado, that was known and is herein referred to as Republic Plaza. During all relevant periods, PFI and BCE were unrelated companies that, prior to 1987, had no business dealings with each other. The investment that Commercial Union initially proposed to PFI involved a lease of Republic Plaza to BCE fpr a period of 26 to 28 years, which was to include a rent holiday2 of approximately 1 year that was to occur at the beginning of the lease term.

During the course of its investigation of the investment proposed by Commercial Union, PFI employed Marshall & Stevens, Inc. (Marshall & Stevens), to prepare an appraisal report (Marshall & Stevens appraisal report). Merle E. Atkins (Mr. Atkins) and John H. Whitcomb (Mr. Whitcomb), who are qualified as experts in the area of real estate appraisal, prepared that report. PFI relied on the Marshall & Stevens appraisal report in evaluating its proposed investment in Republic Plaza, including, inter alia, the reasonableness of the rent holiday included as part of that investment.

On June 14, 1988, partnership was formed pursuant to a partnership agreement entered into. between BCE and PFI (partnership agreement). During all relevant periods, partnership, a general partnership governed by the laws of Colorado, maintained its books and records and filed its Forms 1065 on a calendar year basis using the accrual method of accounting.

In connection with the formation of partnership, a series of interrelated events occurred. Contemporaneous with the formation of partnership, on June 14, 1988, pursuant to a written purchase agreement (purchase agreement), PFI purchased an undivided 35-percent interest in Republic Plaza from BCE, whereupon BCE owned a 65-percent undivided interest therein.

Immediately thereafter, also on June 14, 1988, PFI and BCE contributed their respective interests in Republic Plaza to partnership. Partnership took ownership of Republic Plaza subject to a promissory note, dated April 30, 1986, that obligated BCE to pay $200 million to Teachers Insurance and Annuity Association (tiaa). Pursuant to an agreement between TIAA and partnership that was entered into as of June 14, 1988, that note was restructured. Effective June 17, 1988, as restructured, partnership became the obligor under the promissory note issued to TIAA (tiaa term loan), the outstanding principal balance of that note was reduced to $177,766,184, the maturity date of that note was changed to May 1, 2011, and that note required monthly payments of varying amounts of principal and interest over the term of the loan until it matured on May 1, 2011.

Pursuant to the lease agreement dated June 14, 1988, partnership leased Republic Plaza to BCE for a fixed term that commenced on June 17, 1988, and ends at midnight on June 1, 2013 (lease term), unless extended at the option of BCE, the lessee. At the time partnership and BCE entered into the lease agreement, tenants occupied approximately 71 percent of Republic Plaza pursuant to existing leases, and approximately 29 percent of that office building was vacant. Pursuant to the lease agreement, BCE became the sublessor with respect to those existing tenants and was given the right to receive rent from them.

In order to satisfy the requirements of TIAA, the mortgagor of Republic Plaza, the lease agreement required monthly payments of rent that were to (1) start on July 1, 1989, and terminate on May 1, 2011, (2) be at least equal to the amounts required to pay the monthly debt service on the TIAA term loan, and (3) be used first to satisfy partnership’s obligations under that loan. Starting on June 1, 2011, after the TIAA term loan was to have been paid in full, the lease agreement required an annual payment of rent for each of the last 2 years of the lease term. In order to service the TIAA term loan during the initial lease period of approximately 11.5 months that began on June 17, 1988, and ended on May 31, 1989, during which the rent to be paid according to the lease agreement was zero (11.5-month period of zero rent), BCE and PFI agreed in the partnership agreement to make total additional capital contributions to partnership on the first day of each month during the period July 1, 1988, through June 1, 1989, in the amount of approximately $1,759,144.

The amounts and due dates of rent payable under the lease agreement that were not required by TIAA in order to service the TIAA term loan were developed through the use of a computer program that took into consideration certain requirements of the lessor and the lessee. Those requirements included (1) creating a schedule for the payment of rent that took account of projected increases in rent in the Denver market for office space (Denver office market) and that not only provided a certain yield for the lessor and its partners3 but also minimized the cost to the lessee and (2) structuring the total amount of rent to be paid during each of the 24 annual lease periods that start on June 1 and end on May 31 (annual lease period) following the 11.5-month period of zero rent (including the amount of rent to be paid monthly to service the TIAA term loan) so that such total amount during each such period was always within 90 percent to 110 percent of the average annual amount of the aggregate rent that was to be paid over those 24 years of the lease term.

Taking into account the foregoing considerations involving the requirements of the TIAA term loan, partnership, pfi, and BCE, the lease agreement contained the following provisions with respect to the amounts and due dates of the rent to be paid under that agreement. It required BCE to pay partnership “net basic rent” (basic rent) in arrears on each installment date throughout the lease term “in an amount equal to the sum of the Basic Rent Portions for all Partners.”4

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Bluebook (online)
107 T.C. No. 7, 107 T.C. 94, 1996 U.S. Tax Ct. LEXIS 38, Counsel Stack Legal Research, https://law.counselstack.com/opinion/republic-plaza-props-pshp-v-commissioner-tax-1996.