HOTELS GO CONDO Tax reform could sink limited partnerships, but these deals should keep sailing along.
By - Eleanor Johnson Tracy

(FORTUNE Magazine) – THE PROSPECT that Congress might tax limited partnerships the same as corporations has given a boost to an alternative real estate investment: the condominium hotel. As an individual owner engaged in the business of renting out his room, the investor in a condo hotel remains eligible for some juicy tax deductions. Congress seems smitten with a plan that the Treasury put forth last November but then abandoned under pressure from real estate interests. The reform would make large limited partnerships subject to double taxation -- first the partnership pays and then the individual partners pay again -- and would eliminate write-offs by the partners. Public offerings of hotel condominiums are registered with the Securities and Exchange Commission and technically are securities. Condo boosters claim their investments offer more flexibility and control than limited partnerships. Since the investor is not tied to a general partner, he can calculate the profit or loss on his rental unit in the way most favorable to him, taking straight-line or accelerated depreciation. As an owner, the investor can write off up to $5,000 a year in furnishings and sell his condo whenever he wishes. But condo investors also face some special risks. Unlike limited partners, they are liable for all the hotel's expenses. If a midseason hurricane empties his Xanadu Palace, the investor still must shell out his share of the costs for such things as upkeep on dining rooms and other common facilities. A former innkeeper named William Q. Dowling is the leading independent broker specializing in condo investments. He started Dowmar Securities Inc. in New York two years ago and underwrote $75 million of hotel sales last year. He says the firm will sell $150 million this year. Dowling, 44, has 15 full-time salesmen and uses 300 independent brokers around the country. He charges commissions of 10% on condo sales. Dowmar has sold eight condo hotels and has a half dozen in the works. The most recent is the 294-room Marco Beach Hilton, 20 miles south of Naples, Florida. Rooms in that hotel averaged a wallet-thumping $180,000 each, about 50% more than the typical construction cost of a luxury beach-front hotel. Dowmar also helped Kemmons Wilson, the founder of Holiday Inns, sell the 443- room Wilson World, a condominium hotel one mile from the main gate of Walt Disney World. Rooms there went for $67,000 each, about average for roadside motels. Condo hotels have also caught the fancy of Wall Street. In 1983 Merrill Lynch underwrote the condo offering of the 400-room Sandestin Beach Hilton in Destin, Florida (at $125,000 a room). Condo buyers get a special bonus. They can stay in their rooms two weeks a year without losing their tax write-offs. But they pay a hefty price for staying longer. The IRS will move in and slash the deductions.