-20- involvement undisclosed and/or petitioner's propensity to enter into undocumented and informal relationships coupled with his aversion to lawyers. Key to our analysis, however, are the circumstances at the time petitioner began his involvement with Ms. Jackson. Her prior enterprise was in bankruptcy, and litigation in Federal court was pending regarding the prior enterprise's contract. Although a corporate entity had been formed (Cities), it was without funding and needed initial capital to pursue the Century project. Ms. Jackson was in a position to offer her business acumen and the preferred status of Cities, her minority-owned corporation. In this regard, Ms. Jackson's most recent business experiences had been less than successful. Petitioner had government and road construction experience, and most importantly, he was a source of funding. Under these circumstances, we find that petitioner's capital investment in the joint venture was $52,000, consisting of the initial $12,000 payment made in June 1986 and the $40,000 insurance payment. These amounts were prerequisites to obtaining the Century project. The remaining advances are to be treated as loans to the joint venture. Having decided that petitioner was engaged in a joint venture, and the allocation of the total amount of advances into discrete categories, we next consider the parties' positionsPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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