Thomas C. Sandoval, Jr. and Bobbie J. Sandoval - Page 6

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          realized from the condemnation sale by buying replacement                   
          property under section 1033.                                                
          C.   Properties That Petitioners Contend or That Respondent                 
               Concedes Are Replacement Properties                                    
               1.   Properties That Respondent Concedes Are Replacement               
               Petitioner bought real property on Jones Maltsberger Road              
          (Jones Maltsberger Road property) in San Antonio on September 26,           
          1990, and 3.164 acres of land in Bexar County on October 7, 1991.           
          Respondent concedes that these properties qualify under section             
          1033 as replacement properties for the Hoefgen Avenue property.             
               2.   The Babcock Road Property                                         
               Gary A. Burnett (Burnett) and petitioner each paid a total             
          of $84,107 to buy 1.329 acres of real property on Babcock Road              
          (Babcock Road property) in San Antonio.  They made those payments           
          on October 30 and December 2 and 3, 1991.  On December 4, 1991,             
          petitioner and Burnett agreed in writing (Babcock Road property             
          agreement) to create a joint venture called “TGR Partnership a              
          Texas general partnership” (TGR I), with a principal place of               
          business at the Jones Maltsberger Road property.  Petitioner and            
          Burnett signed Exhibit A to the Babcock Road property agreement             
          which states:  “This partnership is formed for the purpose of               
          purchasing the property as described in Exhibit ‘B’”.  Exhibit B            
          describes the Babcock Road property.  The Babcock Road property             
          agreement provided:  (a) “Joint venture I” began on December 3,             

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