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associated with Newtowne's construction of petitioner's home,
infra.
Meeks was not aware that petitioner received cost savings
from Newtowne when he assisted in the preparation of petitioner's
1984 return. Meeks was also not aware that Newtowne acted as the
general contractor for the construction of petitioner's home.
(b) Saltergate I
On July 30, 1982, petitioner, acting as general partner of
two limited partnerships, purchased two office buildings from
Newtowne for $430,000 and $50,000, respectively. The limited
partnerships participated in a real estate construction project
known as Saltergate Village Phase I. Petitioner received credits
for syndication and consulting fees from Newtowne in the amounts
of $110,000 and $10,000, respectively, which were applied to the
purchase price of the office buildings. The $120,000 in credits
petitioner received was not reported as income on his 1982
return.
On December 1, 1982, petitioner caused the two limited
partnerships to enter into separate "Market Research Analysis and
Ongoing Planning [Agreements]" with Newtowne. The agreements
were signed on behalf of both parties by petitioner. On July 30,
1982, petitioner caused checks to be drawn on the accounts of the
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