Robert C. Austin - Page 5

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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              
               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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