Albert J. and Helen R. Desantis - Page 26

                                       - 26 -                                         

          limited partnerships totaling $120,000 payable to Newtowne.                 
          Petitioner caused the checks to bear a notation indicating that             
          payment was for warranty and/or market research fees.  The                  
          partnerships did not owe Newtowne any amounts for warranty and/or           
          market research fees in 1982.  The checks were endorsed to the              
          Huntington Mortgage Co. and deposited into an account entitled              
          "Newtowne III" at Huntington Bank.  These checks represent the              
          amounts referred to above as syndication and consulting fees.               
          Huntington Bank issued a loan commitment letter to petitioner               
          setting forth the provisions of loans in the amount of $320,000             
          for the purchase of the two office buildings.                               
               (c)  Construction of Petitioner's Home and Architectural               
          Services                                                                    
               As a condition to signing one of the contracts between a               
          partnership that petitioner controlled and Newtowne, petitioner             
          approached Riat with the prospect of swapping petitioner's home             
          for Riat's home.  Instead of swapping homes, Riat suggested that            
          he design and build, with Newtowne, a 10,000-square-foot home for           
          petitioner.  The parties entered into a contract to build the               
          home in November 1983, and construction began shortly thereafter.           
               On February 28, 1985, Newtowne and petitioner entered into a           
          separation agreement.  The construction of the home was not                 
          completed at the time Newtowne entered into the separation                  








Page:  Previous  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  35  Next

Last modified: May 25, 2011