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Petitioners resided in Houston, Texas, at the time they filed
their petition. For the year at issue, they were husband and wife;
they divorced in 1995.
Petitioner’s Employment: 1983-88
Petitioner emigrated to the United States from Great Britain
in 1983. Almost immediately he obtained employment with Mainland
Savings Association (Mainland), a savings and loan association
located in Houston, to computerize their commercial lending and
service operations. Later, after demonstrating an ability to
manage complex real estate investment transactions, he became head
of Mainland’s commercial lending branch, charged with overseeing a
$1.5 billion commercial loan portfolio. Petitioner’s employment
with Mainland ended in early 1986 after Mainland was placed in
receivership by the Federal Savings and Loan Insurance Corporation
(FSLIC). Thereafter, he began to explore different business
opportunities in which to invest. He attempted to establish a
chain of Fuddrucker restaurants in the United Kingdom. He also
attempted to develop a wildlife safari park in Jamaica. Neither
venture materialized.
In May 1986, petitioner was approached by Eastdil Realty, Inc.
(Eastdil), a real estate investment bank based in New York that
specializes in managing large (typically over $400 million) real
estate portfolios for major corporations and others, and was
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