- 2 - FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and supplemental stipulation of facts are incorporated herein by this reference. At the time the petition was filed, petitioners resided in New Milford, Connecticut. Petitioner was a practicing attorney during the relevant period. Petitioners timely filed their 1990 Federal income tax return using the cash receipts and disbursements method of accounting. Prior to June 29, 1987, Raymond Staron held an option to purchase commercial property located at 1835 Post Road East in Westport, Connecticut, for which he had paid $100,000. Hereinafter, 1835 Post Road East will be referred to as the property. The property consisted of approximately one-half acre with four separate buildings. Raymond Staron sought out others who would be willing to invest in the property. On June 29, 1987, petitioner, Bernard Staron, George Allingham, and Raymond Staron purchased the property for $1.2 million. They acquired title to the property as tenants in common. The purchasers financed 100 percent of the purchase price with a $1.2 million loan from Citytrust. Each of the individual purchasers signed a note and mortgage on the property for the $1.2 million loan.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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