Chester F. and Faye L. Sidell - Page 4




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          under Massachusetts law and constitute grantor trusts for Federal           
          income tax purposes.  All income, deductions, and credits of these          
          trusts were reported as pass-through items on petitioners' 1993 and         
          1994 Federal income tax returns.                                            
               On November 8, 1985, Manche Realty Trust acquired title to the         
          land and building known as the Everett Mill Cotton Weaving House            
          (the Everett Mill property), located at 181-183 Canal Street,               
          Lawrence, Massachusetts.  The Everett Mill property is located in           
          a National Register historical district.  Immediately after its             
          purchase in 1985, the Everett Mill property was leased to KGR, Inc.         
          (KGR), Mr. Sidell's wholly owned corporation.  At the time of its           
          acquisition, the Everett Mill property was in poor condition.               
          On July 6, 1992, Mr. Sidell executed an agreement for the                   
          acquisition of the land and building known as Kunhardt Mill,                
          located at 60 Island Street, Lawrence, Massachusetts.  The Kunhardt         
          Mill property is a historic mill dating back to the late 1800's and         
          is located across the street from the Everett Mill property in the          
          same National Register historical district.  On October 14, 1992,           
          CFS Realty Trust (rather than Mr. Sidell) took title to the                 
          Kunhardt Mill property.  At the time of its acquisition, the                
          Kunhardt Mill property needed substantial repair.  After its                
          acquisition, the Kunhardt Mill property was leased to KGR.  The             
          property was subsequently renovated and thereafter used as KGR's            
          corporate headquarters.                                                     





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