- 16 - general partner, to make short-term or GAP loans to the limited partnerships at an interest rate of 2 percent above the prime rate. The GAP sheets purport to record that petitioner made such loans and that the limited partnerships paid interest to petitioner. The record does not reflect that the limited partnerships made payments of principal to petitioner. Petitioner caused checks to be issued from the partnerships payable to himself, bearing the notation "second mortgage interest". The second mortgage interest is attributable to second mortgage loans purportedly made by petitioner to the partnerships. The record does not reflect the terms of any second mortgage loans. Furthermore, there is no evidence that petitioner transferred any funds to the partnerships in accordance with the purported second mortgage loans. Petitioner also caused the partnerships to pool funds to purchase jumbo certificates of deposit during the years at issue. A jumbo certificate of deposit is a certificate of deposit in the amount of $100,000 or more. Petitioner owned rental properties in the Ohio State University and other Columbus, Ohio, areas. During the years in issue, petitioner owned from 31 to 79 such rental properties. Petitioner hired several independent contractors (the laborers) to clean and repair the rental units. Petitioner would present the laborers with their weekly paychecks which they, in turn,Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011