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inquiries advanced to the point of negotiating for any of the
properties they saw.
Petitioner’s situation changed markedly in TYE 8/31/92. The
taxable year began with the enactment of Ordinance No. 3465
requiring petitioner to relocate by January 1, 1995. If this
were not sufficient to impress petitioner’s management with the
urgent need for resolute action, shortly thereafter they received
a strong foretaste of the fate that awaited when, in November,
county officials closed petitioner’s complex and business
stopped. Now Krontz’ searches bore fruit. A property was
identified in Mira Loma. An offer of $1.15 million was made; a
counteroffer of $1.25 million was received. Negotiations over
details of the transaction carried over into the next taxable
year. There is no evidence that petitioner made any loans
unrelated to its business in TYE 8/31/92.
Once petitioner’s management had concrete prospects of an
investment exceeding $1 million, the likelihood that they took
this into account in their financial planning greatly increases.
How much they could reasonably have accumulated for this purpose
is not clear. The Mira Loma deal would have involved seller
financing: to acquire the property petitioner would have had an
immediate need for only the $100,000 downpayment. But there
would have been various other costs as well, including
construction costs and costs to secure permits and favorable
zoning. Petitioner did not prove exactly how much it would have
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