FIRST AMENDMENT CONDOMINIUM OFFERING PLAN. 252 Condominium 252 EAST 57 TH STREET NEW YORK, NEW YORK DOCX

Transcription

1 FIRST AMENDMENT TO CONDOMINIUM OFFERING PLAN 252 Condominium 252 EAST 57 TH STREET NEW YORK, NEW YORK DATED: June 11, DOCX

2 TABLE OF CONTENTS SECTION PAGE INTRODUCTION I 1. PAYMENT IN LIEU OF TAXES (PILOT) INCOME TAX DEDUCTIONS FOR RESIDENTIAL UNIT OWNERS SCHEDULE A - OFFERING PRICES AND RELATED INFORMATION INCORPORATION OF PLAN DEFINITIONS NO MATERIAL CHANGES EXHIBIT A - LETTER FROM SPONSOR'S REAL ESTATE TAX COUNSEL B - IRS RULING DATED SEPTEMBER 16, 2014 C - ATTORNEY INCOME TAX OPINION D - UPDATED SCHEDULE A - OFFERING PRICES AND RELATED INFORMATION DOCX

3 FIRST AMENDMENT TO CONDOMINIUM OFFERING PLAN INTRODUCTION This First Amendment modifies and supplements the terms of the Condominium Offering Plan for the premises known as 252 Condominium ("Condominium") located at 252 East 57th Street, New York, New York ("Property"), dated August 20, 2014 ("Plan"), and should be read in conjunction with the Plan. The terms of this Amendment are as follows: 1. PAYMENT IN LIEU OFT AXES (PILOT) As set forth in the Plan, the Property is exempt from real estate taxes. Similar to other qualified leasehold condominiums, the Lease requires Tenant to make PILOT payments in lieu of taxes. See the Lease Rental and PILOT Schedule set forth in Part II of the Plan, which sets forth the PILOT payable by the Residential Unit Owners, the Retail Unit Owners and the Rental Unit Owners during the Term of the Lease. As set forth in the letter dated April 28, 2015 issued by Marcus & Pollack LLP, Sponsor's real estate tax counsel, a copy of which is annexed hereto as Exhibit "A," the Condominium benefits from a belowmarket, fixed PILOT schedule until April 30, 2035, after which time the amount of PILOT payable by the Residential Unit Owners will be equal to the amount of real estate taxes that would otherwise be payable if the Property were not exempt from real estate taxes. 2. INCOME TAX DEDUCTIONS FOR RESIDENTIAL UNIT OWNERS As set forth in the Plan, on June 26, 2014, Sponsor applied for a ruling from the Internal Revenue Service ("IRS") concerning the deductibility of PILOT by Residential Unit Owners for federal income tax purposes. On September 16, 2014, Sponsor received a favorable ruling from the IRS, which states that PILOT payments will constitute real estate taxes allowable as a deduction under IRS code Section 164. As such, Residential Unit Owners who itemize their deductions and who use their Residential Units as personal residences will be entitled to deduct from their gross income for federal income tax purposes and New York State and New York City income tax purposes their pro rata share of PILOT, subject to certain limitations. Purchasers should refer to (i) the IRS Ruling dated September 16, 2014, annexed hereto as Exhibit "B" and (ii) the Attorney's Income Tax Opinion prepared by Olshan Frome Wolosky LLP, tax counsel to Sponsor, a copy of which is annexed hereto as Exhibit "C." DOCX

4 3. SCHEDULE A- OFFERING PRICES AND RELATED INFORMATION Annexed hereto as Exhibit "D" is an updated "Schedule A - Offering Prices and other Related Information" which reflects the current Purchase Prices for the Units offered for sale. 4. INCORPORATION OF PLAN The Plan, as modified and supplemented by this Amendment, is incorporated herein by reference with the same effect as if set forth at length. 5. DEFINITIONS Any term used in this Amendment not otherwise defined herein shall have the same meaning ascribed to it in the Plan. 6. NO MATERIAL CHANGES Except as set forth in this Amendment, there have been no material changes of facts or circumstances affecting the Property or the offering. SPONSOR: SNOWPLOW LH2 LLC W:ISS\ \0FFERINGIAMDCOND0\ DOCX 2

5 EXHIBIT "A" LETTER FROM SPONSOR'S REAL ESTATE TAX COUNSEL DOCX

6 MARCUS & POLLACK LLP ATTORNEYS AT LAW INCLUDING PROFESSIONAL CORPORATIONS 708 THIRD AVENUE I ITH FLOOR NEW YORK, NY JOEL R. MARCUS ROBERT M. POLLACK PHILIP H. AZARIAN BRUCE A. BRASKY JESSICA L. GOLDSTEIN EMILY N. BLATT ZACHARY L. NATHANSON (212) FAX: (212) taxappeal@marcuspollack.com Snowplow LH 2 LLC 950 Third A venue, 18th Floor New York, New York April 28, 2015 Re: 252 East 5ih Street Block 1330, Lot 15, Manhattan Dear Ladies and Gentlemen: The above-referenced multiple dwelling located at 252 East 5ih Street in Manhattan will be a leasehold condominium building to be constructed upon land owned by the NYC Educational Construction Fund. The Residential Condominium Section will contain 346,868 gross square feet and consist of 93 separately assessed residential condominium tax lots located on the 36-65th floors of the building. Since the Cityowned land is fully exempt from real estate tax.es, the unit owners will make payments in lieu of taxes ("PILOT") under the terms of the ground lease. The PILOT payments through April 30, 2035 will be paid pursuant to a fixed schedule established in the ground lease. After that date, the PILOT payments will be based upon the equivalent fully assessed market real estate taxes. For comparative purposes, you have asked us to prepare an analysis comparing the scheduled PILOT charges to what full real estate taxes would be if the Residential Condominium Section was not exempt from real estate tax.es and what real estate taxes would be if the Residential Condominium Section had been certified as eligible to receive a 10-year partial real estate tax exemption under the 421-a Program. For the purposes of this comparative analysis, you have asked us to assume that the Residential Condominium Section qualified for 421-a benefits via the purchase of negotiable certificates. Enclosed please find our estimated projections comparing (i) what full real estate taxes would be exclusive of any real estate tax exemption benefit, (ii) real estate taxes payable if the Residential Condominium Section was eligible to receive a 10 year pa1tial tax exemption benefits under the 421 -a Program and (iii) Actual PILOT payments imposed for the 93-unit Residential Condominium Section for calendar years and the partial calendar year through April 30, 2035 (based upon the fixed schedule of payments for 2017-April 30, 2035).

7 MARCUS & POLLACK LLP Page 2 April 28, 2015 The attached summary of our analysis is subject to the disclaimers attached thereto. You are authorized to include a copy of this letter in your offering plan for the project. The projections being provided herewith are estimates and are based upon our understanding of the policies, procedures and practices of the Department of Finance (DOF) and are not intended to be a guarantee or assurance that the tax assessments and taxes herein listed will be attained. While we believe our estimates are well founded, they are not intended, and should not be construed as representations or warranties that the assessments and taxes will be determined as set forth herein. The foregoing analysis is based upon our experience with DOF and the Tax Commission of the City of New York, and their assessment practices. Application of a particular approach to valuation by an individual assessor may yield a significantly different result. No representation is made that the current policies and practices of the DOF will apply in the future. You should be aware that the laws, regulations, policies and practices of the DOF, upon which this opinion is predicated may, in the future, be revised in a manner adverse to your interests, or that there may be an adverse interpretation of the law or regulations by one or more agencies of the City of New York, or courts of competent jurisdiction. The figures are approximations which we relied, in part, upon the material submitted by you. We offer no wananties on the Actual assessments, transitional assessments, exemptions, abatements or real estate taxes for any period. Please be advised that Marcus & Pollack LLP does not warrant or guarantee the accuracy of any estimate of Real Estate Taxes provided herein, or that they are free from clerical, computational or mathematical errors. The assessments, and amount of physical increase, if any, when established by the Department of Finance, may be significantly higher or lower than projected. This estimate does not include Business Improvement District (BID) payments that may apply. Actual and transitional assessed valuations adopted for real estate tax projections may deviate from calculated estimates. This estimate is not intended as a guarantee or warranty, nor are any assurances given that it does not contain any computational errors. MP:sm Attachments Very truly yours, (V\vwv rr~)? L~P Marcus & Pollack LLP

8 MARCUS & POLLACK LLP SUMMARY 252 East 57th Street Projected Real Estate Taxes and Actual PILOT Payments for 93-Unit Residential Condominium Section (iii) Actual PILOT (ii) Taxes w/ 10 year Payments for a Capped East Sih Street per Calendar Year (i) Full Taxes Benefits ground lease 2017 $3,823,916 $3,823,916 $2,516, $4,838,002 $4,315,837 $2,784, $5,168,859 $4,108,864 $2,961, $5,537,733 $4,445,938 $3,359, $5,945,765 $4,821,217 $3,770, $6,394,130 $5,235,845 $4,036, $6,727,973 $5,534,939 $4,238, $6,929,812 $5,700,987 $4,606, $7,137,706 $5,872,017 $4,734, $7,351,838 $6,058,320 $4,819, $7,572,393 $6,247,370 $4,869, $7,799,564 $7,799,564 $4,881, $8,033,551 $8,033,551 $5,128, $8,274,558 $8,274,558 $5,302, $8,522,795 $8,522,795 $5,701, $8,778,478 $8,778,478 $5,966, $9,041,833 $9,041,833 $6,205, $9,313,088 $9,313,088 $6,356, (through 4/30/2035) $3,197,494 $3,197,494 $2,127,467 This chart is a summary of our analysis and is su bj ect to the disclaimers attached thereto

9 EXHIBIT "B" IRS RULING DATED SEPTEMBER 16, 2014 W :\SS\ \0FFERINGIAMDCOND0\ DOCX 2

10 Internal Revenue Service Index Number: David Lowenfeld Managing Member Snowplow LH 2 LLC 950 Third Avenue, 18 1 h Floor New York, New York Department of the Treasury Washington, DC [Third Party Communication: Date of Communication: Month DD, YYYY] Person To Contact: Lewis Saideman, ID No Telephone Number: (202) Refer Reply To: CC:ITA:B03 PLR Date: September 16, 2014 Taxpayer= Snowplow LH 2 LLC (EIN: ) Affiliate 1 = Snowplow LH LLC, an affiliate of the Taxpayer Affiliate 2 = Snowplow LH 1 LLC, an affiliate of the Taxpayer Property= 252 East 57th Street, New York, New York Adjacent Property= 226 East 57th Street, New York, New York and currently leased to Whole Foods Market Group, Inc. State 1 = Delaware State 2 = New York Act= NYC Educational Construction Fund Act, Chapter 999, Article 10 of the Education Law of 1966 Fund = New York City Educational Construction Fund City = New York, New York Date 1 =April 28, 2010 Date 2 = December 27, 2013 Date 3 =April 30, 2035 A= 40

11 PLR Dear Mr. Lowenfeld: This is in response to the letter sent by your attorneys dated June 13, In the letter, your attorneys requested a private letter ruling that certain payments in lieu of taxes ("PILOT") are deductible under section 164 of the Internal Revenue Code as real property taxes under the circumstances described below. FACTS Taxpayer is a limited liability company created and existing under the laws of State 1 to consummate development of the Property. State 2 created the Fund, pursuant to the Act, as a State 2 corporate governmental agency, constituting a political subdivision and public benefit corporation for the benefit of the people of the City and State 2 and to facilitate the timely construction of elementary and secondary school buildings in combination with buildings of other compatible and lawful uses. The legislative purpose of the Act is: the timely and responsive provision of such combined occupancy structures in accordance with the foreseeable needs of the [City] for additional or replacement elementary and secondary educational facilities and the desirability of facilitating maximum and appropriate utilization of available land. As part of its program, the Fund contemplated the construction of high-rise structures on air rights or air space above school structures. Some of these high-rise structures were leased on a long-term basis to cooperative housing corporations and more recently, to condominiums. The Act provides in part that "the monies and properties of the [F]und, including all properties constructed, acquired, reconstructed, rehabilitated or improved by it or on its behalf and all properties under its jurisdiction, control or supervision, and all of its operations and activities shall be exempt from taxation." Thus, under the Fund's originating legislation, the Fund's real property is exempt from real property taxes. The Act also provides that: Whenever the easements, space rights, air rights or other fee or leasehold interests held or retained by such owner or developer, if other than the [City] housing authority, and/or the non-school improvements constructed or erected therein or thereon, shall be exempt from real property taxes..., such lease, sublease or other agreement shall also provide for the payment to the fund of annual or other periodic amounts equal to the amount of real property taxes that would otherwise have been paid or payable with respect to such easements, space rights, air rights or other fee or leasehold interests, and with respect to the non-school improvements constructed or erected therein or thereon, over the term of such lease, sublease or other agreement.

12 PLR~ The foregoing provision of the Act was intended to furnish the Fund with the monies necessary to meet debt service on obligations which it would issue for the purpose of obtaining monies to pay the cost of construction of the school portion of the combined occupancy structure. Therefore, instead of the City collecting the real estate taxes on the space rights covered by the leasehold and then paying a rental to the Fund in an amount sufficient for it to meet its obligations, the Act utilizes a direct tax equivalency payment. Taxpayer will be the tenant under a lease of the land underlying the Property upon which the building will be constructed. The fee owner of the Property and the landlord under the lease is the Fund, which acquired the land underlying the Property by deed from the City on Date 1. Taxpayer plans to convert its leasehold interest in the Property to a qualified leasehold condominium. The landlord of the leasehold condominium will be the Fund as of the recording date of the condominium declaration, and after approximately A years following the conveyance of the land to the Fund, the landlord's interest will revert to the City. The condominium will consist of three sections: a res idential section with apartments which will be sold to third parties, a rental unit with rental apartments, and the retail section which will consist of several retail units. Taxpayer intends to sell certain units in the condominium which are part of the residential section to third parties pursuant to a leasehold condominium offering plan approved by State 2's Attorney General. Each purchaser of a condominium unit will acquire from Taxpayer a qualified leasehold condominium interest in the condominium unit and a proportionate undivided interest in the common elements of the condominium for the balance of the leasehold term. Each owner of a condominium unit shall pay their proportionate share of the common charges for the residential section of the condominium to the condominium's board of managers. As of Date 2, Affiliate 1 is the tenant under a lease with the Fund, covering the Property and Adjacent Property. Pursuant to the lease, upon receipt of the first temporary certificate of occupancy for a condominium unit in the building and Affiliate 1 's delivery to the landlord of a notice of its intention to create the condominium, the lease will be severed into two leases, one covering the Adjacent Property, under which Affiliate 2 will be the tenant, and one covering the condominium, under which Taxpayer will be the tenant. Taxpayer will then submit the Property to condominium ownership by recording a declaration and will immediately assign the Taxpayer's interest in the lease covering the condominium to the condominium's board of managers which will thereafter become the tenant under that lease. The Adjacent Property will not be part of the condominium. The Property is exempt from City real estate taxes because the Fund holds fee title to the land underlying the Property, and after the reversion, the City will hold fee title to the land. Similar to other qualified leasehold condominiums, the condominium lease requires the Taxpayer, as tenant, to make PILOT in amounts similar to the amount of real estate taxes that would otherwise by payable if the Property were not exempt from

13 PLR real estate taxes. Unlike real estate taxes, PILOT is not separately billed to each unit owner. Rather, PILOT is collected by the condominium's board of managers from the unit owners pro rata in accordance with their interest in the residential section and included with their proportionate common charges for their condqminium units and paid to landlord under the condominium lease. The condominium lease specifies the amount of PILOT payable by each of the three sections of the condominium for specific periods of years during the term of the condominium lease. The amount of PILOT allocable to the residential section is fixed until Date 3. RULINGS REQUESTED (1) The PILOT to be made pursuant to the Act and the condominium lease will constitute real property taxes allowable as a deduction to the payer under section 164. (2) After the Property is converted to a condominium form of ownership, the unit owners will be entitled to deduct as real property taxes under section 164 that portion of the common charges paid by the unit owners to the condominium board as applied by the condominium board toward the PILOT. A taxpayer may not rely on a private letter ruling that has been issued to another taxpayer. Section of Rev. Proc , l.R.B.50. Therefore, a private letter ruling addresses only the tax liability of taxpayers who are party to the ruling request. However, Taxpayer will be the owner of units in the condominium until the units are sold, and as such, will be liable for PILOT until the units are sold. We consider Taxpayer's second ruling request in that context. LAW AND ANALYSIS Section 164 allows as a deduction the state, local and foreign real property taxes paid or accrued in the taxable year. Section (b) of the Income Tax Regulations defines real property taxes as taxes imposed on interests in real property that are levied for the general public welfare. Assessments for local benefits are not treated as real property taxes. See sections (g) and of the regulations. Whether a particular charge is a "tax" within the meaning of section 164 depends on its true nature as determined under federal law. The designation given by local law is not determinative. A charge will constitute a tax if it is an enforced contribution, exacted pursuant to legislative authority in the exercise of taxing power, and imposed and collected for the purpose of raising revenues to be used for public or governmental purposes. See Rev. Rul , C.B.103; Rev. Rul , C.B. 42. Rev. Rul involved tax equivalency payments to the New York City Ed ucational Construction Fund, a public benefit corporation, by a cooperative housing corporation. The payments were applied to debt service on obligations fu nding public school construction. The ruling holds that the cooperative housing corporation may deduct the

14 PLR payments as real property taxes under section 164 because: (1) The payments are measured by and are equal to the amounts imposed by the regular taxing statutes, (2) the payments are imposed by a specific state statute (even though the vehicle of a lease agreement is used), and (3) the proceeds are designated for a public purpose rather than for some privilege, service, or regulatory function, or for some other local benefit tending to increase the value of the property upon which the payments are made. Accordingly, each tenant-stockholder of the cooperative housing corporation may deduct the payments in the amount of the stockholder's proportionate share. The PILOT obligations in this case will satisfy the three-prong test of Rev. Rul because they: (1) are imposed at the same general rate at which real property taxes are imposed; (2) are imposed pursuant to the Act as implemented by the condominium lease; and (3) may only be used for public purposes. Accordingly, we hold as follows: 1. The PILOT payments to be made pursuant to the condominium lease to the Fund (or to City should it reacquire the Property) will constitute real property taxes allowable as a deduction to the payor under section Taxpayer as a unit owner will be entitled to deduct as real property taxes under section 164 that portion of the common charges paid by Taxpayer to the condominium board as applied by the condominium board towards the PILOT obligations. This ruling is directed only to the taxpayer requesting it. Section 611 O(k)(3) provides that it may not be used or cited as precedent. In accordance with the Power of Attorney on file with this office, a copy of this letter is being sent to your authorized representative. A copy of this letter must be attached to any income tax return to which it is relevant. Alternatively, taxpayers filing their returns electronically may satisfy this requirement by attaching a statement to their return that provides the date and control number of the letter ruling.

15 PLR The rulings contained in this letter are based upon information and representations submitted by the taxpayer and accompanied by a penalty of perjury statement executed by an appropriate party. While this office has not verified any of the material submitted in support of the request for rulings, it is subject to verification on examination. Sincerely, (C 1~~ Christopher F. Kane Chief, Branch 3 Office of Associate Chief Counsel (Income Tax & Accounting) cc: Internal Revenue Service Attn: Industry Director, Natural Resources and Construction (LB&l:NRC) 1919 Smith Street, Stop 1000-HOU Houston, TX 77083

16 EXHIBIT "C" ATTORNEY INCOME TAX OPINION W;ISS\26360\1\0FFERINGIAMDCOND0\ DOCX 3

17 OLSHAN PARK AVENUE TOWER 65 EAST 55TH STREET NEW YORK, NEW YORK TELEPHONE: FACSIMILE: DIRECT DIAL: November 10, 2014 Snowplow LH 2 LLC 950 Third A venue, l 8 1 h Floor New York, NY Re: 252 Condominium Gentlemen: In connection with the offering of condominium units under a plan entitled Condominium Offering Plan for 252 Condominium (the "Plan"), you have requested our opinion as special tax counsel to the Plan concerning certain tax matters. Specifically, you have requested our opinion as to the deductibility for federal and New York State income tax purposes of payments of. mortgage interest and payments in lieu of taxes ("PILOT") by individual Residential Unit Owners. You have also asked for our opinion as to the tax status of the condominium association. All capitalized terms not otherwise defined herein shall have the same meaning ascribed to them in the Plan. We understand that under the Plan each Residential Unit Owner will hold title to a leasehold condominium interest in his Unit and undivided leasehold in the Common Elements of the Condominium. Under New York State law, each Unit and its interest in the Common Elements will be assessed as a separate parcel for PILOT purposes. Each Residential Unit Owner may place a separate mortgage on his Unit and, by doing so, incur direct liability for the interest payable on such mortgage. In our opinion under present law, subject to the limitations discussed in the following paragraph and subject to limitations imposed on the deduction of itemized deductions, interest on a mortgage secured by a Residential Unit paid or accrued by the owner of such Residential Unit who is liable for the interest payment on such mortgage and who uses the Residential Unit exclusively as his personal residence will be deductible for federal income tax purposes in the appropriate year according to his method of accounting, provided that he itemizes his deductions. 1 In rendering this opinion we assume that such interest is not prepaid, that the 1 We note that there appears to be no provision in Code Sections I 63(h)(3) or 12 l that would prohibit deduction of interest on a mortgage used to purchase a condominium unit as a residence subject to a ground lease as the case here. In Rev. Ru! , 1970~2 CB 9, the IRS held that sales proceeds received by a developer that constructed condominium apartments on its land and transfe1ted such apartments to individuals together with 75 year leases of the land were properly treated as amounts received from sale of property and not amounts received rrom leases. In Rev. Rul , l CB 27, the IRS stated that a sale of a life estate in a taxpayer's principal residence would be O LSHAN FROME WOLOSKY LLP

18 November 10, 2014 Page 2 mortgage proceeds were used by the Residential Unit Owner to purchase the Residential Unit, that the Residential Unit is the owner's principal residence and that the Residential Unit Owner is an individual. Except as provided below, residential interest is deductible if paid or accrued during the taxable year on indebtedness which is secured by either the taxpayer's principal residence, as defined for purposes of exclusion of gain on sale under Internal Revenue Code ("Code") Section 121, or on certain designated second homes. However, a ceiling is placed on the amount of indebtedness which may be taken into account for purposes of this deduction. In general, with respect to indebtedness incurred in purchasing a Residential Unit, this ceiling is $1,000,000, or $500,000 in the case of a married individual filing a separate return. In addition, an individual may deduct interest on an additional $100,000 of indebtedness in excess of the $ 1,000,000 limit mentioned above (or $50,000 of indebtedness in excess of the $500,000 limit in the case of a married individual filing a separate return) as interest on home equity indebtedness. However, special limitations may apply to the deductibility of points and prepaid interest if any.. Sponsor has obtained a ruling from the Internal Revenue Service dated September 16, 2014, which states that PILOT payments made will constitute real property taxes allowable as a deduction under Code Section 164 and (ii) that the Sponsor as the original owner of the Residential Units will be able to deduct as real property taxes under Code Section 164 the portion of the common charges that the Sponsor pays to the Condominium Board that arc applied by the Condominium Board to PILOT obligations. Since the PILOT obligations paid by the Sponsor are deductible as real estate taxes under Code Section 164, each individual Residential Unit Owner as transferee of the Sponsor will be able to deduct PILOT payments as real estate taxes. Thereby it is our opinion that payments made by an individual Residential Unit Owner to the Condominium Board that will be applied by the Condominium Board to PILOT obligations will be deductible as real estate taxes by an individual Residential Unit Owner for federal income tax purposes in the appropriate year according to his method of accotmting, provided he itemizes deductions. We note that in some cases the amount of mortgage interest deductible by an individual Residential Unit Owner subject to the alternative minimum tax may be less than the amow1t deductible by a Residential Unit Owner subject to the regular income tax and that no deduction is allowed for real estate taxes paid by a taxpayer subject to the alternative minimum tax. The mortgage interest and PILOT described above will also be allowable as deductions for New York State income tax purposes to a resident individual. W c express no opinion with respect to these items under the New York State personal income tax on nonresidents. We also express no opinion as to the taxation of Residential Unit Owners who are not individuals. considered the sale ofa principal residence under Code 121 ifthe life estate is the taxpayer's entire interest in the residence. These two revenue rulings indicate that when a taxpayers' acquisition of less than a fee interest in a condominium unit may still be treated as a residence of a taxpayer for purposes of deducting interest on a mortgage used to purchase such residence. We also note that tenant-stockholders of cooperative housing corporations are allowed to deduct interest on a loan secured by their shares when the cooperative housing corporation's building is built on land leased to a third party

19 November 10, 2014 Page 3 We have reviewed various documents included as exhibits in the Plan relating to the organization of the Condominium Board of 252 Condominium (the "Association"), including the Declaration of Condominium and By-Laws of the Condominium (which are the instruments which will create the Association). Our opinion has been requested as to whether the Association will be eligible to qualify as a tax-exempt organization for federal income tax purposes. In order for the Association to qualify as an exempt organization for federal income tax purposes under Code Section 528, it must meet the following six conditions: (1) The Association must be organized and operated to provide for the acquisition, construction, management, maintenance, and care of the Association's property. (2) Sixty percent (60%) or more of the Association's gross income for the taxable year must consist solely of arnow1ts received as membership dues, fees or assessments from owners of Residential Units. (3) Ninety percent (90%) or more of the expenditures of the Association for the taxable year must be expenditures for the acquisition, construction, management, maintenance, and care of the Association's property. ( 4) No part of the net earnings of the Association may inure to the benefit of any private shareholder or individual, other than by acquiring, constructing, or providing management, maintenance, and care of the Association's property and other than by a rebate of excess membership dues, fees, or assessments. (5) The Association must qualify as a "condominium management association," which is an organization meeting the requirements of condition (1 ), above, with respect to a condominium project substantially all the units of which arc used by individuals for residences. year. (6) The Association must properly elect to have Code Section 528 apply for the taxable "Substantially all the units" of a condominium management association will be considered as used by individuals for residences if at least eighty-five percent (85%) of the total square footage of all Units within the project is used by individuals for residential purposes. Units that are used for purposes auxiliary to residential use are considered as used for residential purposes. These auxiliary purposes include laundry areas, storage rooms, and areas used by maintenance personnel. A special limitation is established for transient use. No building or Unit will be considered as used for residential purposes if, for more than one half the days in the Association's taxable year, such Unit or building is occupied by a person or series of persons each of whom occupies the Unit or building for less than thirty days. You have advised us that more than 85% of the total square footage of the Premises will be used by individuals for residential purposes and that no person may rent his Residential Unit for a period of less than thirty (30) days. Accordingly, the "substantially all" test should initially be met

20 November 10, 2014 Page4 Our review of the documents referred to above indicates that the Association meets all the organizational tests described above for qualification for exemption. Assuming the Plan is consummated in accordance with its provisions and that the Association, in its actual operation, meets the other tests set forth above, it is our opinion that the Association will be eligible to elect tax-exempt status under Code Section 528. If such exempt status is properly elected, it is our opinion that the Association will not be subject to federal income tax for the taxable years in which such election is in effect, except as noted in the following paragraph. An effective election will exempt from federal income taxation all amounts received by the Association as exempt function income. This consists of amounts received as membership dues, fees, or assessments from owners of Residential Units. However, the Association will be subject to tax on income which is not exempt function income to the extent such income exceeds expenses properly allocable to such income. Examples of income which is not exempt function income are interest earned on reserve funds, amounts received from persons who are not members of the Association, amounts received for work done on privately owned property which is not Association property, and amounts received from members for special use of the Association's facilities, the use of which is not available to all members as a result of having paid the dues, fees, or assessments required to be paid by all members. If the Association fails to qualify as a "homeowners association", or if it does but chooses not to make the necessary election, the present state of the law is uncertain as to the tax treatment of any income of the Condominium in excess of appropriate deductions and credits. Tax authorities may take the position that the Condominium is a separate taxable entity and that some or all of its income (including the nonmembership, and possibly membership, income described above less expenses related to such income) is subject to Federal corporate income tax, New York State Corporation Franchise Tax and New York City Corporate Franchise or Unincorporated Business Tax. Alternatively, it is possible that some or all of such income might be reportable directly by the Residential Unit Owners. The tax treatment of the Condominium may be affected by certain United States Treasury Department regulations relating to entity classification. This opinion deals only with the specific tax matters discussed above, which do not necessarily comprise all tax matters which may be significant to purchasers of Units. We express no views as to any federal, New York State or New York City tax consequences other than as explicitly discussed in this opinion or as to the tax status or tax consequences of the Plan under the laws of any foreign jurisdiction. Accordingly, it is recommended that each prospective purchaser of a Unit consult with his or her own tax advisor concerning the federal, New York State, and New York City tax consequences of the purchase and ovmership of a Unit. This opinion is based solely on the facts and documents referred to above. No warranties arc made that the tax laws upon which counsel bases this opinion will not change. In no event will the Sponsor, counsel to Sponsor, special tax counsel to the Sponsor, the Association, or any other person be liable if, by reason of fl.1ture changes in fact or applicable law, regulations, decisional law, or Internal Revenue Service rulings, the tax consequences described previously should change

21 November 10, 2014 Page 5 ALL RESIDENTIAL UNIT OWNERS, POTENTIAL RESIDENTIAL UNIT OWNERS AND THE CONDOMINIUM ARE HEREBY INFORMED THAT (1) ANY TAX ADVICE CONTAINED IN THIS OPINION IS NOT INTENDED OR WRITTEN TO BE USED, AND CANNOT BE USED, FOR THE PURPOSE OF A VOIDING PENALTIES UNDER THE INTERNAL REVENUE CODE, (IT) THE ADVICE IS WRIITEN TO SUPPORT THE PROMOTION OR MARKETING OF THE TRANSACTIONS OR MATTERS ADDRESSED IN THE PLAN, AND (III) EACH RESIDENTIAL UNIT OWNER, EACH POTENTIAL RESIDENTIAL UNIT OWNER, AND THE CONDOMINIUM SHOULD SEEK ADVICE BASED ON ITS PARTICULAR CIRCUMSTANCES FROM AN INDEPENDENT TAX ADVISOR

22 EXHIBIT "D" UPDATED SCHEDULE A- OFFERING PRICES AND RELATED INFORMATION W:\SS\26360\1\0FFERINGIAMDCOND0\ DOCX 4

23 SCHEDULE A 252 EAST 57TH STREET CONDOMINIUM 252 EAST 57TH STREET NEW YORK, NY OFFERING PRICES AND RELATED INFORMATION PROJECTED COMMON CHARGES AND REAL ESTATE TAXES ARE FOR THE FIRST YEAR OF CONDOMINIUM OPERATION - JANUARY 1, DECEMBER 31, 2017 (1) (2) (2) (3) (4) (4) (5) (SA) (6) (6A) (7) (7A) UNIT 36A 36B 36C 36D 37A 37B 37C 37D 38A 38B 38C 38D 39A 39B 39C 39D 40A 40B 40C 40D 41A 41B NUMBER OF BEDROOMS/ BATHS/ POWDER ROOMS 3/3/0 3/3/0 3/3/0 3/3/0 3/3/0 3/3/0 3/3/0 APPROX APPROX UNIT SQ. TERRACE FT. SQ. FT. 2, , , , , , , , , , , , , , , , , , , , , ,924 0 OFFERING PRICE $4,875,000 $4,685,000 $4,875,000 $4,685,000 $4,925,000 $4,735,000 $4,925,000 $4,735,000 $4,975,000 $4,785,000 $4,975,000 $4,785,000 $5,025,000 $4,835,000 $5,025,000 $4,835,000 $5,175,000 $4,985,000 $5,175,000 $4,985,000 $5,225,000 $4,985,000 % OF RESIDENTIAL COMMON INTEREST % % % % % % % % % % % % % % % % % % % % % % %OF COMMON INTEREST % % % % % % % % % % % % % % % % % % % % % % PROJECTED ANNUAL COMMON CHARGES (EXCLUDING PILOT) $47, $44, $46, $44, $47, $44, $47, $44, $47, $44, $47, $44, $47, $44, $47, $44, $47, $44, $47, $44, $47, $44, PROJECTED MONTHLY COMMON CHARGES (EXCLUDING PILOT) $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, $3, ANNUAL PILOT $21, $20, $21, $20, $21, $20, $2 1, $20, $21, $20, $21, $20, $21, $20, $21, $20, $2 1, $20, $21, $20, $21, $20, MONTHLY PILOT $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, $1, PROJECTED ANNUAL COMMON CHARGES (INCLUDING PILOT) $68, $64, $68, $65, $68, $64, $68, $65, $68, $64, $68, $65, $68, $64, $68, $65, $68, $64, $68, $65, $68, $64, PROJECTED MONTHLY COMMON CHARGES (INCLUDING PILOT) $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5, $5,412.31

24 41C 3/3/0 2, $S,22S,OOO % 0.46S7% $47, $3, $21,3S6.96 $1,779.7S $68, $S, /3/0 1,926 0 $4,98S,OOO % % $44, $3, $20, $1, $6S,01S.22 $S, A 3/3/1 2, $S,7SO,OOO % O.S092% $S1, $ $23,3S1.79 $1,94S.98 $74,82S.04 $6,23S.42 42B 2/2/1 1,7SO 0 $4,19S,OOO % % $40,6S8.17 $3, $18,44S.33 $1,S $S9,103.S1 $4,92S.29 42C 3/3/1 2, $S,7SO,OOO % O.S087% $S1, $4,28S.S6 $23, $1, $74,7S7.49 $6, /2/1 1,742 0 $4,19S,OOO % % $40, $3, $18, $1,S30.08 $S8, $4, A 3/3/1 2, $S,810, % O.S093% $S1, $4, $23,3SS.S2 $1, $74, $6, B 2/2/ 1 1,749 0 $4,240, % % $40,6SS.18 $3, $18, $1,S37.00 $S9, $4, C 3/3/1 2,19S 71 $S,810, % 0.S088% $S1, $4,286.2S $23, $1,944.S4 $74, $6, D 2/2/1 1,741 0 $4,240, % % $40, $3, $18,3S9.62 $1,S29.97 $S8, $4, A 3/3/1 2,19S 72 $S,870, % O.S091% $S1, $4, $23, $1,94S.72 $74,81S.08 $6,234.S9 44B 2/2/1 1,747 0 $4,28S,OOO 0.732S% % $40, $3,38S.74 $18, $1,S36.01 $S9, $4,921.7S 44C 3/3/1 2, $S,870, % O.S086% $S1, $4, $23,327.S9 $1, $74, $6, D 2/2/1 1,739 0 $4,28S,OOO % % $40, $3, $18, $1,S28.97 $S8,790.S2 $4, SA 3/3/1 2, $S,930, % O.S092% $S1, $4, $23,3SS.03 $1,946.2S $74,83S.41 $6, SB 2/2/1 1,746 0 $4,330, % % $40,62S.87 $3,38S.49 $18, $1,S3S.89 $S9,0S6.S6 $4, SC 3/3/1 2, $S,930, % O.S088% $S1, $4,286.1S $23, $1, $74, $6,230.6S 4SD 2/2/1 1,738 0 $4,330, % % $40, $3, $18, $1,S28.8S $S8,78S.96 $4, A 3/3/1 2,193 7S $S,990, % O.S093% $S1,488.S3 $4, $23,3S8.73 $1,946.S6 $74, $6, B 2/2/1 1,74S 0 $4,37S,OOO % % $40, $3,38S.23 $18, $1,S3S.77 $S9,0S2.10 $4, C 3/3/1 2, 191 7S $S,990, % O.S089% $S1, $4, $23, $1, $74,779.S8 $6, D 2/2/1 1,736 0 $4,37S,OOO % % $40, $3, $18, $1,S27.8S $S8,747.S3 $4,89S.63 47A 3/3/1 2, $6,0S0, % O.S092% $S1, $4,289.4S $23,3S1.8S $1,94S.99 $74,82S.23 $6,23S.44 47B 2/2/1 1,743 0 $4,420, % % $40,S96.42 $3, $18, $1,S34.78 $S9,013.7S $4, C 3/3/1 2, $6,0S0, % O.S087% $S1, $4,28S.S7 $23, $1, $74,7S7.S2 $6, D 2/2/1 1,73S 0 $4,420, S% % $40, $3,367.S1 $18, $1,S27.73 $S8, $4,89S.24 48A 3/3/1 2, $6,110, % O.S093% $S1, $4, $23,3SS.S3 $1, $74, $6, B 2/2/1 1,742 0 $4,46S,OOO % 0.401S% $40,S93.30 $3, $18,41S.90 $1,S34.66 $S9, $4, C 3/3/1 2, $6,110, % 0.S088% $S1, $4, $23, $1,944.S3 $74, $6, D 2/2/1 1,733 0 $4,46S,OOO % 0.399S% $40,383.S7 $3,36S.30 $18, $1,S26.73 $S8, $4, A 3/3/1 2, $6,1 70, % O.S092% $S1, $4, $23,3S1.27 $1,94S.94 $74,823.3S $6,23S.28 49B 2/2/1 1,740 0 $4,S10, % % $40,S66.83 $3,380.S7 $18, $1,S33.66 $S8, $4, C 3/3/ 1 2, $6,170, % O.S087% $S1,42S.46 $4,28S.4S $23, $1, $74,7SS.S7 $6, D 2/2/1 1,732 0 $4,S10, % % $40, $3,36S.03 $18, $1,S26.61 $S8, $4, SOA 3/3/1 2, $6,34S,OOO % 0.S092% $S1,480.1 S $4, $23,3S4.93 $1, $74,83S.08 $6, SOB 2/2/1 1,739 0 $4,640, % % $40,S63.6S $3, $18,402.4S $1,S33.S4 $S8, $4, soc 3/3/1 2,18S 80 $6,34S,OOO % 0.S088% $S1,433.SO $4, $23, $1, $74, $6, SOD 2/2/1 1,730 0 $4,640, S% % $40,3S3.72 $3, $18, $1,S2S.60 $S8, $4, S1A 3/3/1 2, $8,3SO,OOO % % $61,7S6.66 $S, $28, $2,334.7S $89, $7, S1B 3/3/0 2,271 0 $6,3SO,OOO 0.9SSS% 0.S243% $S2, $4, $24, $2, $77, $6, S1C 3/3/1 3,0S4 81 $9,3SO,OOO % % $71,74S.08 $S, $32,S48.49 $2, $104,293.S7 $8, S2A 3/3/1 2, $8,S00, % % $61,7S2.27 $S, $28,01S.07 $2,334.S9 $89, $7, S2B 3/3/0 2,269 0 $6,42S,OOO 0.9SS1% O.S241% $S2, $4, $24, $2, $77, $6,417.81

25 S2C ,0SO 83 $9,S2S, % % $71,698.9S $S, $32,S27.S6 $2, $104,226.SO $8,68S.S4 S3A , $8,6SO,OOO 1.113S% % $61,76S.37 $S, $28, $2,33S.08 $89, $7, S38 2,268 0 $6,S00, SS2% 0.S241 % $S2, $4,41S.1S $24, $2, $77, $6, S3C , $9,700, % % $71,670.2S $S,972.S2 $32,S14.S4 $2,709.SS $104, $8, S4A ,621 8S $8,800, % % $61,7SS.07 $S, $28, $2, $89, $7,480.9S S48 2,266 0 $6,S7S,OOO 0.9S48% O.S239% $S2, $4, $24, $2, $76, $6,41S.68 S4C ,043 8S $9,87S,OOO % % $71, $S, $32, $2,707.S7 $104, $8,67S.7S SSA , $8,9SO,OOO % % $61, $S,14S.39 $28,011.6S $2, $89,7S6.39 $7, SS8 2,264 0 $6,770, S44% 0.S237% $S2, $4, $24,017.S6 $2, $76,9S8.33 $6, SSC , $10,200, % % $71,S6S.90 $S, $32, $2,70S.60 $104, $8, S6A SISl 1 4, $19,000, % 1.1SS7% $116, $9,736.3S $S3, $4, $169,841.0S $14,1S3.42 S , $1 0,22S, % % $70,8S8.S3 $S, $32, $2, $103, $8,S83.74 S7A SISl 1 4, $19,SOO,OOO 2.10S8% 1.1SS4% $116, $9,733.8S $S2, $4,41S.94 $169, $14, S , $10,SOO,OOO % 0.700S% $70, $S, $32,12S.03 $2, $102, $8,S78.06 S8A SISl 1 S, $21,2SO,OOO % % $123,82S.10 $10, $S6,17S.S6 $4, $180,000.6S $1S,000.0S S81S98 SISl 1 4,S16 0 $18,6SO,OOO % % $10S,7S7.76 $8,813.1S $47, $3,998.2S $1S3, $12, S9A SISl 1 S, $21,7SO,OOO 2.231S% % $ $10,31S.07 $S6,1SS.49 $4, $179, $14, A Sl611 4, $18,2SO,OOO % % $109, $9, $49, $4, $1S8, $13, , $13,1SO,OOO % 0.779S% $78, $6,S66.S8 $3S, $2,979.0S $114,S47.S9 $9,S4S.63 61A Sl611 4,624 9S $18,S7S,OOO 1.96S1 % % $109,004.SS $9, $49,4S1.94 $4, $1 S8,4S6.48 $13, ,331 9S $13,400, % % $78,679.S8 $6,SS6.63 $3S,694.4S $2,974.S4 $114, $9,S A Sl611 4, $18,900, % % $108, $9,073.S3 $49,396.S1 $4, $1 S8, $13, , $13,6SO,OOO % % $78,S42.43 $6,S4S.20 $3S, $2,969.3S $114, $9,S14.SS 63A Sl611 4, $19,22S,OOO % 1.07S8% $108,7S4.14 $9, $49, $4,111.S3 $1 S8, $13, ,31S 98 $13,900, % 0.77SS% $78, $6,S33.27 $3S,S67.27 $2, $113,966.SO $9, A Sl611 4, $19,800, S84% % $108, $9,0S2.63 $49,282.7S $4, $1S7,914.3S $13,1S9.S , $14,32S,OOO % % $78, $6,S21.81 $35,S04.89 $2, $113, $9,480.SS PH6S , $37,SOO,OOO 3.469S% % $192, $16, $87, $7,27S.68 $279, $23, SUBTOTAL RESIDENTIAL UNITS 236,531 4,859 $ 751,460, % % $5,546, $462, $2,516, $209, $8,063, $671, RENTAL UNIT 194,560 NIA NIA NIA % $1,S42,6SO.OO $128,SS4.17 $1,697, $141, $3,240, $270, RETAIL A 8,083 NIA NIA NIA % $65, $5,4S8.12 $53, $4, $118, $9, RETAIL 8 7,947 NIA NIA NIA % $64, $S, $S2, $4, $1 16, $9, RETAILC 18,269 NIA NIA NIA % $148, $12, $120, $10, $268, $22, RETAIL D 1,435 NIA NIA NIA % $1 1, $ $9, $ $21, $1, SUBTOTAL COMMERCIAL UNITS 230,294 NIA NIA NIA % $1,832, $152, $1,933, $161, $3, 765, $313, STORAGE 1 NIA 69 NIA $8S,000 NIA NIA $1, $ NIA NIA $1, $ STORAGE 2 NIA 53 NIA $66,000 NIA NIA $1, $87.53 NIA NIA $1, $87.53 STORAGE 3 NIA 103 NIA $120,000 NIA NIA $2, $ NIA NIA $2, $ STORAGE 4 NIA 106 NIA $120,000 NIA NIA $2, $ NIA NIA $2, $ STORAGE 5 NIA 102 NIA $120,000 NIA NIA $2, $ NIA NIA $2, $168.46

26 STORAGE 6 N/A 78 N/A $95,000 N/A N/A $1, $ N/A N/A $1, $ STORAGE 7 N/A 43 N/A $52,500 N/A N/A $ $71.02 N/A N/A $ $71.02 STORAGE 8 N/A 51 N/A $65,500 N/A N/A $1, $84.23 N/A N/A $1, $84.23 STORAGE 9 N/A 43 N/A $52,500 N/A N/A $ $71.02 N/A N/A $ $71.02 STORAGE 10 N/A 34 N/A $44,000 N/A N/A $ $56.15 N/A N/A $ $56.15 STORAGE 11 N/A 34 N/A $44,000 N/A N/A $ $56.15 N/A N/A $ $56.15 STORAGE 12 N/A 44 N/A $48,000 N/A N/A $ $72.67 N/A N/A $ $72.67 STORAGE 13 N/A 47 N/A $57,500 N/A N/A $ $77.62 N/A N/A $ $77.62 STORAGE 14 N/A 43 N/A $52,500 N/A N/A $ $71.02 N/A N/A $ $71.02 STORAGE 15 N/A 43 N/A $52,500 N/A N/A $ $71.02 N/A N/A $ $71.02 STORAGE 16 N/A 43 N/A $52,500 N/A N/A $ $71.02 N/A N/A $ $71.02 STORAGE 17 N/A 63 N/A $79,000 N/A N/A $1, $ N/A N/A $1, $ STORAGE 18 N/A 41 N/A $49,500 N/A N/A $ $67.71 N/A N/A $ $67.71 STORAGE 19 N/A 47 N/A $57,500 N/A N/A $ $77.62 N/A N/A $ $77.62 STORAGE 20 N/A 69 N/A $85,000 N/A N/A $1, $ N/A N/A $1, $ STORAGE 21 N/A 67 N/A $75,000 N/A N/A $1, $ N/A N/A $1, $ STORAGE 22 N/A 69 N/A $85,000 N/A N/A $1, $ N/A N/A $1, $ STORAGE 23 N/A 94 N/A $11 5,000 N/A N/A $1, $ N/A N/A $1, $ STORAGE 24 N/A 43 N/A $52,500 N/A N/A $ $71.02 N/A N/A $ $71.02 STORAGE 25 N/A 43 N/A $52,500 N/A N/A $ $71.02 N/A N/A $ $71.02 STORAGE 26 N/A 43 N/A $52,500 N/A N/A $ $71.02 N/A N/A $ $71.02 STORAGE 27 N/A 43 N/A $52,500 N/A N/A $ $71.02 N/A N/A $ $71.02 STORAGE 28 N/A 79 N/A $95,000 N/A N/A $1, $ N/A N/A $1, $ STORAGE 29 N/A 42 N/A $52,500 N/A N/A $ $69.37 N/A N/A $ $69.37 STORAGE 30 N/A 45 N/A $56,000 N/A N/A $ $74.32 N/A N/A $ $74.32 STORAGE 31 N/A 45 N/A $56,000 N/A N/A $ $74.32 N/A N/A $ $74.32 STORAGE 32 N/A 45 N/A $56,000 N/A N/A $ $74.32 N/A N/A $ $74.32 STORAGE 33 N/A 81 N/A $97,500 N/A N/A $1, $ N/A N/A $1, $ STORAGE 34 N/A 66 N/A $82,500 N/A N/A $1, $ N/A N/A $1, $ STORAGE 35 N/A 52 N/A $65,500 N/A N/A $1, $85.88 N/A N/A $1, $85.88 STORAGE 36 N/A 50 N/A $63,500 N/A N/A $ $82.58 N/A N/A $ $82.58 STORAGE 37 N/A 36 N/A $44,500 N/A N/A $ $59.46 N/A N/A $ $59.46 STORAGE 38 N/A 36 N/A $44,500 N/A N/A $ $59.46 N/A N/A $ $59.46 STORAGE 39 N/A 37 N/A $44,500 N/A N/A $ $61.11 N/A N/A $ $61.11 STORAGE 40 N/A 54 N/A $67,500 N/A N/A $1, $89.19 N/A N/A $1, $89.19 STORAGE 41 N/A 127 N/A $155,000 N/A N/A $2, $ N/A N/A $2, $ STORAGE 42 N/A 52 N/A $65,000 NIA N/A $1, $85.88 N/A N/A $1, $85.88 STORAGE 43 N/A 48 N/A $59,000 N/A N/A $ $79.28 N/A N/A $ $79.28 STORAGE 44 N/A 60 N/A $74,000 N/A N/A $1, $99.09 N/A N/A $1, $99.09 STORAGE 45 N/A 59 N/A $73,000 N/A N/A $1, $97.44 N/A N/A $1, $97.44 STORAGE 46 N/A 36 N/A $44,500 N/A N/A $ $59.46 N/A N/A $ $59.46 STORAGE 47 N/A 92 N/A $112,500 N/A N/A $1, $ N/A N/A $1, $ STORAGE 48 N/A 45 N/A $56,000 N/A N/A $ $74.32 N/A N/A $ $74.32

27 STORAGE 49 NIA 66 NIA $82,500 NIA NIA $1, $ NIA NIA $1, $ STORAGE 50 NIA 100 NIA $120,000 NIA NIA $1, $ NIA NIA $1, $ SUBTOTAL STORAGE 2,911 NIA $ 3,550,500 NIA NIA $57, $4, NIA NIA $57, $4, PARKING 1 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 2 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 3 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 4 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 5 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 6 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 7 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 8 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 9 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 10 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 11 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 12 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 13 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 14 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 15 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 16 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 17 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 18 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 19 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 20 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 21 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 22 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 23 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 24 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 25 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 26 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING27 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 28 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 29 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 30 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 31 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 32 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 33 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 34 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 35 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 36 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 37 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 38 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $ PARKING 39 NIA NIA $400,000 NIA NIA $2, $ NIA NIA $2, $176.78