- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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