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particular offer, and petitioner made all decisions regarding the
disposition of the residences. Petitioner did not have a
contractual right to dispose of the residences or to convey the
residences to itself. Petitioner's control over the residences
does not make it the owner of the residences. When a property
owner grants an option to purchase property, the owner may
relinquish control over the disposition of the property but
retain ownership of the property until the option is exercised.
See Penn-Dixie Steel Corp. v. Commissioner, 69 T.C. 837, 844-845
(1978).
We view petitioner's control over the residences to be a
form of security for petitioner to control the amount of its
relocation expenditures. The purpose of the deed in blank was to
facilitate the sale to a third party because many employees moved
to the new location before the third-party sale occurred. It was
not the purpose of the deed in blank to enable the RSC to gain
title to the property. The contracts of sale also protected
petitioner so that it would be indemnified for its equity and
maintenance payments. To that end, the contracts of sale
provided that in the event that the employees defaulted, the
equity payment was refundable. Upon refund of all money received
from the RSC, the contracts of sale would terminate. The default
and termination provisions are inconsistent with the acquisition
of equitable ownership of the residences. We find that
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