Margaret Hancock - Page 4

               Petitioner and her husband jointly ran Hancock Enterprises.             
          Petitioner designed houses, developed floor plans, worked with               
          subcontractors to compute sale prices, ran the sales office, sold            
          houses, supervised assistants, created sales brochures, met with             
          accountants at Toback & Co. to discuss financing, engaged in                 
          public relations, and handled customer complaints.  Hancock                  
          handled the acquisition of property and obtained acquisition and             
          development loans.  After Hancock obtained the initial loans,                
          petitioner met with the banks and arranged for construction and              
          operating loans.                                                             
               Hancock Enterprises built five to seven model homes in each             
          of its subdivisions and had salespeople in the model homes.  It              
          sold the model homes when it no longer needed them.  Hancock                 
          Enterprises built all the homes except the model homes for                   
          specific buyers.                                                             
               Hancock Enterprises developed the Summer Shadows and Camelot            
          Village subdivisions in 1976 or 1977, the Playa Del Sur                      
          subdivision in 1977, and the Estate La Colina, Estate Los                    
          Arboles, and Paradise Village North subdivisions in 1978.  In                
          1977 and 1978, Hancock Enterprises was offering lots for sale in             
          at least five subdivisions.                                                  
               Until the 1980's, Hancock Enterprises sold all of the model             
          homes after it completed a subdivision.  Beginning in the 1980's,            

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