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made DPPs much less valuable to investors,
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and so a lot of wealthy people switched from DPPs to REITs.
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Before 1986, the tax law
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allowed use of DPPs as a tax loss device.
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People would invest in buildings solely for tax purposes
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because you could write off the depreciation on the building,
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so people were cynically setting up DPPs as tax shelters only.
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Congress said, finally--I think wisely--in 1986,
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that we don't want to create rules that
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encourage people to do a different sort of business
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just to evade taxes.
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So, they made a--they said that losses that