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returns on a calendar year basis.
Jaussaud Enterprises
Jaussaud Enterprises is a California corporation with a fiscal
year ending February 28. At all relevant times, petitioner was the
sole shareholder and sole officer of Jaussaud Enterprises.
Jaussaud Enterprises operated an equipment leasing business,
providing trash cans and containers for the rubbish pickup
industry. The corporation's principal customer was PJB, a
corporation all the stock of which was owned by petitioner and his
mother (who died in 1988, leaving petitioner as the sole
shareholder of PJB). By 1991, Jaussaud Enterprises' business
activity was minimal.
Transfer of Real Property
Jaussaud Enterprises was the owner of improved real property
located at 905 N. Hidalgo Avenue, Alhambra, California (the
Alhambra property). Located on the Alhambra property was a house
in which petitioner resided.
Petitioner decided to sell the Alhambra property. A potential
buyer of the Alhambra property was found, and on June 11, 1990,
petitioner, on behalf of Jaussaud Enterprises, executed escrow
instructions at Atla Escrow Corp. (Atla Escrow) pursuant to which
the Alhambra property was to be sold for $329,000 to Ming Eo
Jessica Sung, an unrelated third party. The escrow instructions
were amended on June 12 and 20, 1990, to account for various
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