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t ~ \~ • • <br />r <br />13. Issuance of a partnership interest in tax-free exchar_ge <br />under Section 721 of the Code for property, at least <br />where the partner purchased the property more than 3 <br />years before the issuance of the bonds. Rev. Rut. 77- <br />146, 1977-1 C.B. 24. <br />14. A cash purchase of a partnership interest. LTR 8316023 <br />(9.99% interest in joint venture); LTR 8320025 (49,0 <br />limited partnership interest if r_o plan to licuidate <br />partrership). <br />15. If the present owner purchased the facility within the <br />six-year period, the purcase price is a capital <br />expenditure but the prior owner's capital expenditures <br />with respect to the facility may be disregarded to the <br />extent they are reflected in the purchase price. Rev. <br />Rul. 70-427, 1976-2 C.B. 28; LTR 79102 1. See LTR <br />8017077; LTR 8239051. <br />16. Cost to rep'_ace property damaged or destroyed by fire, <br />storm, or other casualty to t~.e exte_^.t not in excess of <br />the fair market value (determined is,.:~ediately before <br />the casualty) of the property replaced. IRC § 103(b) <br />(6)(c)(~)(i); Treas. Reg. § 1.103-10(b)(2)(iv)(c); LTR <br />8124151. <br />17. Expenditure by a Section 501(c)(3) charitable orcar_iza- <br />tion for charitable activities are not capital extendi- <br />tures for purposes of a related person's small issue <br />financing of an unrelated facility. Rev. Rul. 74-289, <br />1974-1 C.B. 32. See LTR 8011062. <br />18. Expenditures by a state or local gover^^ental unit paid <br />or incurred in carrying out its sta~utory purposes are <br />not capital expenditures for purposes o_` a small issue <br />financing of an unrelated facility. LTR 8012090; LTR <br />8317083 (computer unrelated to building in which it is <br />used). <br />19. Expenditures by a public utility which is not the <br />principal user of the bond-financed facility with <br />respect to property of such compare or by a State or <br />local governmen*_al unit wit h respect ~o ..:e prop erty of <br />such unit, if the following ce^~i;.'_ons are me;.: ( i ) <br />Such property is used to rovi~e cas, wager, sewage <br />disposal services, elect__c energy, or telechore <br />-1C- <br />