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corporation, Michael C. Hollen, D.D.S., Professional Corporation
(P.C.).
On March 17, 1982, petitioners and two other married couples
purchased a fruit and flower farm in San Diego County,
California, from Hugh D. and Bonnie B. Lentz (Mr. and Mrs.
Lentz). The property was known as the Blue Bird Ranch (the
ranch) and was acquired for $1,138,750. Petitioners and the
other purchasers executed a promissory note in the amount of the
purchase price and a deed of trust to secure payment of the note.
Title to the ranch was conveyed to petitioners and the other
purchasers as tenants in common.
On or about April 1, 1982, petitioner and the other two
husbands formed the partnership to operate and manage the ranch.
The wives did not participate in the partnership.3
Although the partners did not reduce their partnership
agreement to writing, they orally agreed that each couple would
contribute its one-third interest in the ranch to the
partnership. Petitioner believed that title to the property had
been transferred to the partnership until he was advised to the
3Although petitioner testified that the wives were not
partners, whether or not the wives contributed capital to the
partnership or were partners as a matter of law is not material
to the decision we reach in this case. Consequently, we do not
make specific findings of fact regarding whether the wives were
partners.
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