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D. Sleiman are entitled to increase their respective stock bases
in their wholly owned S corporations, Real Estate Equities, Inc.
(REE) and Triple Net Equities, Inc. (TNE), by the principal
amounts of bank loans to REE and TNE which they personally
guaranteed; (2) whether respondent properly reallocated Miramar
Equities, Inc.'s (ME's) bases in its land and depreciable real
property; (3) the proper amortization period for a loan
commitment fee and attorney's fees incurred by ME during 1992 in
connection with obtaining a loan; (4) whether REE and ME are
entitled to deductions pursuant to section 164(a) for taxes
incurred in connection with recording mortgages in the State of
Florida; and (5) whether REE and TNE are required to report
tenant improvements as rental income.
Some of the facts have been stipulated and are so found.
The stipulations of fact and attached exhibits are incorporated
herein by this reference. Petitioners resided in Jacksonville,
Florida, on the date their respective petitions were filed.
Petitioners Eli T. Sleiman (Eli), Peter D. Sleiman (Peter),
and Anthony T. Sleiman (Anthony) are brothers. All three
participated with a fourth brother, Joseph E. Sleiman, who is not
a party to these cases, in various real estate development
projects in northern Florida.
The brothers ordinarily divided up the different aspects of
their real estate development activities among themselves. Eli
is a licensed contractor who oversees the construction
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