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Petitioner received a degree in finance and banking
from Texas Tech University in 1969. After graduation,
petitioner was employed until 1972 by Shell Oil as a
financial analyst. He then became employed by Vernon
Savings & Loan (Vernon). In 1981, he became Vernon's
president and chairman of its board. Petitioner left
Vernon's employ in April 1986. For general background
regarding petitioner and others involved in these cases,
see Federal Sav. & Loan Ins. Corp. v. Dixon, 835 F.2d
554 (5th Cir. 1987); Little v. Commissioner, T.C. Memo.
1996-270.
Moonlight Beach Club Issue
During 1981, Mr. Don R. Dixon, a real estate
developer in Dallas, Texas, bought a controlling interest
in Vernon's stock. Several months later, he transferred
the stock to a wholly owned company, Dondi Financial, Inc.,
that was formed for the purpose of holding the stock.
After acquiring Vernon, Mr. Dixon caused all of his
controlled corporations engaged in the real estate
development business to be merged into or acquired by
Vernon. He then formed Dondi Associates, Inc. (Dondi
Associates), a Texas corporation, that was owned by members
of his family for the purpose of engaging in real estate
development.
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