Allen M. Glick - Page 3

                                        - 3 -                                         
                                   FINDINGS OF FACT                                   

               Some of the facts have been stipulated and are so found.               
          The first and second stipulations of facts are incorporated                 
          herein by this reference.                                                   
               Petitioner resided in Framingham, Massachusetts, when he               
          filed his petition in this case.  In 1981, petitioner purchased             
          approximately 380 acres of real property (Eastleigh Farm) located           
          primarily in Framingham, Massachusetts, with portions also in               
          Marlborough and Southborough, Massachusetts.                                
               In late 1983 or early 1984, Barry Walker and Kenneth                   
          Dallamora approached petitioner about the possibility of                    
          purchasing a portion of Eastleigh Farm for their company,                   
          Eastleigh Development Corp. (Eastleigh Development).  On January            
          23, 1984, petitioner conveyed approximately 48.26 acres of                  
          Eastleigh Farm to Eastleigh Development.  On September 28, 1984,            
          petitioner also conveyed approximately 29.653 acres of Eastleigh            
          Farm to Eastleigh Development.  Eastleigh Development subdivided            
          the parcels and built and sold homes on this property.                      
               On March 22, 1984, in connection with the transfer of the              
          two small parcels, petitioner and Eastleigh Development entered             
          into an agreement whereby Eastleigh Development was to install a            
          sewer pipeline (the Eastleigh Sewer Line) from its nearby                   

               2(...continued)                                                        
          sec. 6621(c) for a substantial underpayment attributable to a               
          tax-motivated transaction.                                                  




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