- 3 -
project." Mr. Grant and petitioner understood that petitioner's
"interest [would] be secured by Joint Title to all projects."
Petitioner and Mr. Grant jointly purchased a vacant lot on
Gracey Lane in Fallbrook, California, on or about September 22,
1989, and by the end of 1990 Mr. Grant had built a single-family
residence on it (we collectively refer to the lot and the
residence as the Property). Petitioner and Mr. Grant did not
enter into a formal partnership agreement with respect to the
purchase of the lot or the building of the residence. Petitioner
financed the residence's construction, and Mr. Grant was the
builder. Mr. Grant supervised the construction and hiring of
crews and subcontractors who participated in the development of
the Property.
After Mr. Grant had built the residence on the lot, the
Property was offered for sale at approximately $389,000. The
Property did not sell as expected, and Mr. Grant realized that he
could not pay petitioner the agreed rate of return on his
investment. In January 1991, Mr. Grant quitclaimed his interest
in the Property to petitioner to allow him to attempt to recover
his promised return. In 1992, petitioner sold the Property for
$279,000. With the exception of this sale and the sale of his
personal residence, petitioner was not involved in any other real
estate sales activity from 1990 through 1994.
Petitioner never maintained a business office with respect
to his participation in the Property, and he did not have a
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011