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thereafter, OPEC cut off the United States' supply of benzene,
and in 1974 Shell stopped producing the resin. With "no relief
in sight", petitioner liquidated the subsidiary in 1976.
Industrial Management, another 80-percent subsidiary,
provided real estate expertise to clients. It acquired and
developed property, designed buildings, found financing, and, if
necessary, dealt with related government legislation.
Far Western, a wholly owned subsidiary, operated a real
estate brokerage business. When petitioner formed Far Western,
Hugh McMahon III (Hugh) provided the necessary brokerage license
required by the California Department of Real Estate. Far
Western operated actively from 1983 until 1985, but Far Western
never generated any taxable income. The only gross income
reported for Far Western was $2,031 in 1984.
Petitioner's other wholly owned subsidiary, Sale By Owner,
experimented with an alternative real estate brokerage business.
For a $290 fee, a homeowner selling his own home could list his
house on the multiple listing service without engaging an
exclusive real estate agent. But, if a broker found a buyer, the
homeowner could use the broker and pay his fee.
Byrne, his wife, and Hugh incorporated Sale By Owner on
April 15, 1982, and obtained a corporate broker's license from
the Department of Real Estate, using Hugh's brokerage license.
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