Albert J. and Helen R. Desantis - Page 25

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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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