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which petitioner held an interest as a general partner. (Another
partnership owned the land in Allison Pointe.) The manner in
which the partnerships were set up to own the different
properties was common in the real estate industry.
Petitioner's principal partners in each of the partnerships
were Dickman, Roger Eiteljorg, and Jim Eiteljorg. Petitioner was
managing general partner of each of the partnerships. For the
sake of simplicity, the partnerships operated collectively under
the name of Citimark. Citimark is not a legal entity and earns
no income. For marketing purposes, petitioner was represented as
the president of Citimark. Similarly, Dickman, Jim Eiteljorg,
and Roger Eiteljorg held themselves out as senior vice presidents
of Citimark.
The partnerships were initially financed with short-term
construction loans that enabled them to build the projects and
lease them up to a point. By 1990 and 1991, the partnerships had
amassed approximately $50 million of debt as a result of short-
term financing, approximately $40 million of which was due in
December 1991. The partners, including petitioner, had assumed
personal liability for the $40 million of loans due as a
condition of obtaining the financing. As managing general
partner, it was one of petitioner's responsibilities to find a
source to refinance the construction loans in the form of long-
term mortgages.
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