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properties. On January 1, 1977, Mr. McKelvey contributed
the shopping center to petitioner. After Mr. McKelvey and
petitioner had rented the shopping center for some time, it
was in need of renovations that would cost approximately
$200,000. Mr. McKelvey decided, on petitioner's behalf, to
sell the properties, and he engaged a real estate agent to
assist in the sale. Petitioner sold the properties on
September 29, 1986, to Ashworth, Inc.
2116 Fort Sill Boulevard, Lawton: Mr. McKelvey
purchased this property and tore down a house that was
on it to make way for a building which he leased. On
January 1, 1977, Mr. McKelvey contributed the property
to petitioner. In 1995, petitioner sold the property to
an individual who had worked for Mr. McKelvey, Mr. Jimmy
Parker, for $290,000. Petitioner financed the sale of the
property. Petitioner did not engage a real estate agent
in connection with the sale.
2112 Fort Sill Boulevard and 1108 Lincoln Boulevard:
Mr. McKelvey purchased a building at 2112 Fort Sill
Boulevard and a house on a contiguous property at 1108
Lincoln Boulevard from a friend. On January 1, 1977, he
contributed the properties to petitioner. Petitioner
leased the properties to Mr. Rick Taylor. In 1985 or 1986,
petitioner renovated the building, and in 1995, petitioner
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