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4. Americana
Before and during the years in issue, petitioner husband
transferred real estate without consideration from petitioners to
Americana, and from Americana to petitioners. During the years
in issue, petitioner husband deposited rental and installment
sales income from real estate owned by Americana to the Earl Kiem
Bell/Shores escrow account, which petitioner husband controlled.
In 1987, petitioner husband transferred $9,800 to
Americana's account. Petitioner husband liquidated Americana in
1987. At that time, he distributed its assets, including
financial investments and real estate to himself and assumed its
liabilities. In 1987, petitioners paid various expenses relating
to real estate owned by petitioners and/or Americana.
From 1987 to 1989, petitioner husband obtained second
mortgages on, and rented, real properties owned by petitioners
and/or Americana. At the same time, he sold parcels of real
estate that were owned by petitioners and/or Americana in 1987,
1988, and 1989. He sold five houses in 1987, three in 1988, and
two in 1989. Also in those years, petitioner husband used funds
invested in Americana to buy real estate for Americana.
Petitioners earned interest of $259 in 1987, $306 in 1988,
and $379 in 1989.
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