3
All section references are to the Internal Revenue Code as
in effect for the years in issue, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
FINDINGS OF FACT
These cases are consolidated for trial, briefing, and
opinion. Some of the facts have been stipulated and are found
accordingly. We incorporate by reference the stipulation of
facts and attached exhibits.
Petitioners are the Estate of Donald H. Ray (Mr. Ray),
Deceased, Patricia G. Ray, (Mrs. Ray) Independent Executrix, and
Patricia G. Ray, and Cipriano Dominguez and the Estate of Isabel
Dominguez (Mrs. Dominguez), Deceased, Cipriano Dominguez,
Independent Executor. At the time the petition was filed in
docket No. 4582-93, Mrs. Ray resided in Arlington, Texas. At the
time the petition was filed in docket No. 4583-93, the
Dominguezes resided in Arlington, Texas.
In 1981, Mr. Ray, Mrs. Dominguez, and Robert F. Breese
(Breese) began investing together in various entities. Breese is
a certified public accountant with a bachelor's degree in
business administration in accounting; however, he does not
actively practice in accounting. They formed RDB Joint Venture
(RDB), a Texas general partnership, and Breese managed RDB's
investments. Mr. Ray died in December 1990, and prior to that
time Mrs. Ray did not actively participate in the Rays'
investments. Mrs. Dominguez died in June 1993.
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