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until later. Petitioner estimates he may have received a couple
of hundred dollars of dividend income from UNAKA in 1988.
Petitioner was also a stockholder of the Austin Company.
The Austin Company was in the tobacco business and was the
company that petitioner's father worked for prior to his
retirement and the purchase of UNAKA. Petitioner is unsure if he
received dividends from the Austin Company in 1988. Petitioner
was not on the board of directors or an employee of the Austin
Company.
Petitioner's father had caused a restaurant to be
constructed and had placed the property in petitioner's name.
This restaurant was the source of rental income to petitioner
during some of the years at issue. As of April 15, 1989,
petitioner knew that the restaurant was being rented, although he
was unaware of the amounts of rental income or expenses.
The only investment that petitioner ever made on his own was
the purchase of two condo time-shares located in Vail, Colorado.
Rental activity was sporadic, and petitioner ultimately disposed
of the time-shares at a loss. Petitioner had purchased a house
in Wyoming as his residence while he worked there, and,
similarly, he had purchased a house in Lindale, Texas, when he
went to work for the East Texas Symphony Orchestra. Petitioner
may have rented out one or both of these residences after he
moved out. None of the real properties that petitioner himself
purchased produced any rental income during 1988.
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