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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.
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