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down; the distributor agreements with the various U.S.
manufacturers were terminated; and in December 1977 petitioner
divested himself of any interest in Diesel Power.
Between 1976 and 1981, however, he became involved in
various closely held corporations and partnerships for real
estate development and farming operations. He formed CDC, which
filed corporate tax returns with its consolidated subsidiaries
including Caspian Electric Company, Caspian Farm Systems, Caspian
Machinery Company, and Charleston, Inc. CDC was generally in the
business of real estate and real estate development and
management. CDC owned 70 percent of Green Prairie, a partnership
consisting of an Alabama farming operation; a second partnership,
Franklin Green, owned a house on the Alabama farm; a third
partnership, the Bowling Green partnership, owned the farm-land.
Petitioner, directly or indirectly (in conjunction with CDC),
owned over 50 percent of these three partnerships. Petitioner
was also a shareholder in the following additional entities:
McZand Corporation, a subchapter S corporation, which held real
estate in the Columbus, Ohio, area; and Homestead Development and
Southern Florida Real Estate, both of which were involved in real
estate development and investment in Florida. By 1978 CTC
employees had become employees of CDC, and although CTC continued
as a Schedule C business, it is unclear on this record exactly
what business CTC engaged in after 1977.
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