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Year Compensation
1982 $294,263
1983 348,630
1984 250,000
1985 356,590
During the years in issue, petitioner Arlene Barlow was not
generally employed outside the home. She did receive some
minimal compensation in 1984 and 1985 working for petitioner’s
professional corporation.
Petitioner is also a sophisticated investor. Prior to
purchasing a partnership interest in Dickinson, petitioner’s
investment portfolio included a variety of interests. For
example, petitioner owned stock in a closely held corporation,
DOTT Manufacturing Co., that formed plastic products for the
automobile industry.7 Petitioner also owned partnership
interests in Wilmington Associates, a “land type of investment”
in North Carolina; 16-75 Land Co., “an investment in an office
building” in Michigan; and Stonebridge Manor Properties, a
partnership whose business is not described in the record.
Petitioner also owned an interest in Greater Mary, an operating
coal mine in Pennsylvania. In addition, petitioner owned stocks
and bonds, including municipal bonds, as well as a communications
system that he rented to a medical clinic.
7 On their income tax return for 1985, petitioners reported
gain from the sale of stock in Dott in the amount of $222,349,
based on a gross sales price of $287,034 and cost or other basis,
plus expense of sale, in the amount of $64,685.
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