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Mr. Canty negotiated all real estate transactions on behalf
of FIIC, OIP, and other petitioners involved in real estate
investment. As far as Mr. Canty was concerned, such negotiations
were not final until a real estate deal was actually closed.
When one of the petitioners was interested in buying certain real
property, as a negotiating tactic Mr. Canty sometimes intention-
ally stalled the closing even after a real estate contract had
been signed. That was because Mr. Canty believed that such a
stalling tactic tended to lower the purchase price.
Petitioners filed consolidated U.S. Corporation income tax
returns (consolidated returns) for the taxable years ended
February 28, 1991, February 29, 1992, February 28, 1993, and
February 28, 1994, on August 24, 1992, December 28, 1992, Novem-
ber 29, 1994, and April 27, 1995, respectively. Each of those
consolidated returns was signed by C. Riggs (Mr. Riggs) as return
preparer.
Claimed Section 1031 Real Estate Transactions
On September 28, 1982, pursuant to a joint venture agree-
ment, OIP, Xway, Inc. (Xway), a Florida corporation, and Alpha
Trust (Alpha), a Florida trust, formed a joint venture under the
name Interstate Park (Interstate). The joint venturers formed
Interstate in order to, inter alia, acquire and develop certain
commercial real property located in Orlando, Florida (commercial
real property), that OIP was in the process of purchasing from
the School Board of Orange County, Florida (School Board). In
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