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A. Andros. Unless otherwise specified, the term “petitioner”
refers to Theodore A. Andros.
Petitioner received a B.A. in economics and psychology from
the University of Nebraska in 1950. He thereafter entered the U.S.
armed services and received the equivalent of an electronics
engineering degree.
Petitioner is an experienced and sophisticated businessman. He
has a basic knowledge of tax law. Petitioner understands the
beneficial treatment accorded to capital gains and knows that
excess losses in 1 year can be carried back to the 3 prior years.
Hy-Gain Electronics Corp.
Petitioner was one of the founders of Hy-Gain Electronics
Corp. (Hy-Gain). Hy-Gain manufactured communications equipment.
From 1972 through 1976, petitioner was the executive vice president
as well as a director and shareholder of Hy-Gain. His brother,
Andrew Andros, was Hy-Gain’s president.
On March 19, 1976, petitioner sold his shares of Hy-Gain stock
for $3.6 million. He realized a $3,492,989 long-term capital gain
from the sale.
Real Estate Transactions
Upon leaving Hy-Gain, petitioner became involved in real
estate transactions, including condominium conversions. By 1979,
he was involved in commercial real estate consulting. He also had
investments in other business enterprises.
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