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Petitioner sold his interest in the Giddonsville Packing Co.
at a loss.
2. McCullen Real Estate and Development Co., Inc.
In 1978, petitioner incorporated McCullen Real Estate and
Development Co., Inc. (McCullen Real Estate). He is president,
sole stockholder, principal agent, and an employee of McCullen
Real Estate.
McCullen Real Estate received commissions when its employees
sold real estate owned by third parties. It also received fees
for managing and appraising real properties. McCullen Real
Estate managed rental units for The A.F.T.E.R. Co. (described
below at par. B-4-c). McCullen Real Estate did not sell real
estate that petitioner owned.
3. Real Estate Business
Petitioner operated a business of appraising and managing
real estate for third parties. Petitioner did not sell any real
property that he owned before or during the years in issue. He
did not advertise that any of his properties were for sale during
the years in issue.
4. Real Estate Partnerships
a. McCullen-Clifton
In 1974, petitioner formed McCullen-Clifton, a general real
estate business partnership. Petitioner's partner in McCullen-
Clifton had experience in the real estate business. McCullen-
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