Hotelerama Associates, Ltd. v. Bystrom

OPINION OF THE COURT

JOSEPH M. NADLER, Circuit Judge.

THIS CAUSE came before the Court for nonjury trial. The Court *77heard testimony, received documentary evidence and considered the parties’ pleadings, closing arguments and memoranda of law. Upon consideration, the Court makes the following findings of fact and conclusions of law.

1. This action was brought by the taxpayer Hotelerama Associates, Ltd. to contest the 1982 tax assessment of two parcels of real property improved by the Fountainbleau-Hilton Hotel complex. The Hotel was purchased by Hotelerama out of bankruptcy for $28,362,239. Prior…