Allie Ray McCullen and Shurley G. McCullen - Page 6

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          Clifton was dissolved in 1978 when petitioner started his own               
          firm.                                                                       
                    b.   Scott-McCullen and Godwin-McCullen                           
               Petitioner formed a partnership with Scott (not otherwise              
          described in the record) to buy, subdivide, and sell real                   
          property.  Scott and petitioner bought, subdivided, and sold real           
          estate over the years.  They intended to have a satellite office            
          in Onslow County.                                                           
               In 1989, petitioner and Douglas Godwin (Godwin) formed a               
          partnership called Godwin-McCullen Real Estate in Dunn, North               
          Carolina.  The record contains no other information about these             
          partnerships.                                                               
                    c.   The A.F.T.E.R. Entities                                      
               The A.F.T.E.R. Co. owned residential rental units which                
          McCullen Real Estate managed.  Petitioner was also involved (the            
          record does not specify how) in A.F.T.E.R. East Associates, which           
          owned a multifamily housing project.                                        
                    d.   Crown Farms Co.                                              
               Petitioner was involved (the record does not specify how)              
          with Crown Farms Co.  Crown Farms bought residential lots.                  
          C.   Petitioner's Farming Activities                                        
               Before the years in issue, petitioner raised cattle,                   
          tobacco, produce, hay, and grain crops.  His largest source of              
          farming income in 1990 and 1991 was poultry.  He built his                  
          poultry facilities in 1968 and has operated them continuously               




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