Thomas C. Sandoval, Jr. and Bobbie J. Sandoval - Page 7

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          1991; (b) its purpose was short-term investment (6 to 12 months)            
          in the Babcock Road property; (c) all allocations would be 50               
          percent each to petitioner and Burnett; (d) real property was to            
          be owned in the name of the joint venture or any joint venturer             
          as nominee or trustee of the joint venture; (e) each joint                  
          venturer waived the right to partition joint venture property;              
          (f) the joint venturers had equal right to control and manage the           
          Babcock Road property; (g) the joint venturers’ rights to sell,             
          assign, transfer, encumber, or otherwise dispose of interests in            
          the Babcock Road property were restricted; and (h) each of the              
          joint venturers had the option to buy the other’s interest upon             
          the other’s death, adjudication of the other’s incompetency, the            
          other’s bankruptcy, or gift of part or all of the other’s                   
          interest in the property.                                                   
               The Babcock Road property settlement statement dated                   
          December 5, 1991, names TGR I as the borrower for the property.             
               On March 20, 1992, petitioner registered TGR I as his                  
          assumed name.  Petitioner did not include Burnett’s name on the             
          assumed name certificate.  A City of San Antonio statement of               
          property taxes for 1992 lists the TGR I as the owner of record of           
          the Babcock Road property.                                                  
               On December 15, 1992, petitioner and Burnett sold the                  
          Babcock Road property for $318,000 plus $429 in taxes.  The                 
          settlement statement listed TGR I as the seller.  Petitioner and            

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