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stationed in France from 1959 to 1961. He returned to the United
States in 1961 and worked for 6 months as a registered
stockbroker in Santa Barbara, California. He then worked for a
home builder in Ventura, California, for about a year and a half.
From 1961 to 1970, he operated his own building company and joint
ventured with another person for 3 years.
After succeeding in the home building business in
California, petitioner moved to New York City to work for Levitt
& Sons, one of the nation's largest single-family-home builders.
After about 3 years, he took a position in Columbus, Ohio, with a
company that built apartment buildings. Petitioner then worked
in Jacksonville, Florida, for a company that built apartment and
condominium buildings.
In 1970, petitioner moved to the San Francisco area to work
for Builders Resources (Builders). Builders' primary business
was providing venture capital to small builders throughout the
United States. Petitioner worked for Builders for about 2 years.
During that time he met Donald R. Dixon (Dixon). Dixon was then
the third largest single-family-home builder in Dallas, Texas.
Builders financed Dixon's Dallas home-building activities.
From 1970 to 1978, petitioner worked on several real estate
developments and syndications and became the chief financial
officer of a residential real estate firm. In 1978, petitioner
moved to France. In 1980, he moved to London and helped to
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