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Ownership and Foreclosure
In 1982, petitioner acquired limited partnership interests
in a partnership named 66 Farmout, both individually and under
the name M & A Interest. In 1983, petitioner acquired limited
partnership interests in three partnerships: Dime Box No. II,
Dime Box No. III, and CAG Farmout. Petitioner owned interests in
Dime Box No. III individually and under the name M & A Interest.
We will refer to 66 Farmout, Dime Box No. II, Dime Box No. III,
and CAG Farmout collectively as the partnerships. The
partnerships were engaged in the activity of drilling oil and gas
wells. Prior to the year in issue, petitioner used portions of
his interests in the partnerships as collateral for loans.
Petitioner used his interests in 66 Farmout as collateral for one
loan in an amount not in the record1 and used his interests in
the remaining partnerships as collateral for another loan in the
amount of $100,000. Petitioner owned the partnerships, and used
the partnership interests as collateral, in the following
percentage amounts:
1 In his trial memorandum, petitioner asserts that the loan
for which the 66 Farmout interests served as collateral was equal
to $15,000. We have no sworn testimony or other evidence to
support this claim, and in any event the amount of the loan is
unimportant to the resolution of the issue in this case.
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