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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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