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partnership, acted as the tax matters partner, and provided
information to the accounting firm that prepared the partnership
returns of income. Petitioner acted as managing partner, with
the primary responsibility of identifying and proposing
properties for purchase by Pecaris and acting on its behalf in
the purchase and sale of properties.
In 1976, Pecaris purchased a strip shopping center known as
the North Shore Mall (the Mall), located in Willowick, Ohio, at a
cost of $2.8 million.
In April 1978, the terms of the Pecaris partnership were
memorialized in a written partnership agreement. Under the terms
of the Pecaris partnership agreement, petitioner and Mr. Spillas
each has a 25-percent interest in profits and losses, and
Mr. Boyas has a 50-percent interest. The Pecaris partnership
agreement contains no express provision regarding how it can be
amended. However, in January 1985, petitioner and Messrs. Boyas
and Spillas executed a written amendment to the Pecaris
partnership agreement that replaced its original provisions
concerning disposition of interests in the partnership on
retirement or death of a partner.
Coastal Partnership
At monthend November 1987, petitioner and Vincent Giorgi
formed Coastal, an Ohio general partnership, for the purpose of
acquiring, owning, leasing, and operating commercial real estate.
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