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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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