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Petitioner Betty L. Barber is also a well-educated
individual. During the years in issue, she was a college
professor at Eastern Michigan University.
Petitioners are financially successful. During the years in
issue, they received both compensation for services and income
from other sources in the total amount (exclusive of partnership
losses) as follows:
1982 1983
$90,990 $70,573
Petitioner is a relatively sophisticated investor, and he
generally made the investment decisions for his family.
Prior to purchasing a partnership interest in Whitman,
petitioner’s investment portfolio included a variety of
interests. For example, in 1978, petitioner invested in
University Associates, a real estate partnership that owned an
apartment complex in San Diego, California. In 1979 through
1981, petitioner invested in several oil and gas partnerships,
including Winer Development Co. In addition, petitioner
maintained an account with a national brokerage firm and invested
in publicly held securities. He also owned a receivable in the
form of a land contract.
Petitioner has a younger brother, John Barber (petitioner’s
brother), who, like petitioner, graduated from the University of
Michigan with a degree in engineering. Since the mid-1970's,
petitioner’s brother has been enrolled to practice before the
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