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Burnett each signed the settlement statement as a partner of TGR
I. The settlement company issued two checks for $143,250 each
payable to TGR I. Petitioner and Burnett each endorsed one check
payable to the other.
3. The Warfield Drive Property
On May 14, 1993, petitioner and Burnett agreed to form a
joint venture under the name “TGR Partnership a Texas general
partnership” (TGR II) to buy real property to hold for 3 to 5
years to generate rental income.
On May 17, 1993, petitioner and Burnett signed a written
agreement (Warfield Drive property agreement), and bought
property on Warfield Drive (Warfield Drive property) in San
Antonio. On May 17, 1993, petitioner and Burnett each paid about
$123,000 for a 50-percent interest in TGR II. Petitioner and
Burnett signed Exhibit A to the Warfield Drive property agreement
which states: “This partnership is formed for the purpose of
purchasing the property as described in Exhibit ‘B’”. Exhibit B
describes the Warfield Drive property. The Warfield Drive
property settlement statement identified “Gary Burnett and Tom
Sandoval dba TGR and Partnership” as the borrower for the
property. The Babcock Road and Warfield Drive property
agreements are identical except for the description of, and the
stated purpose for holding, the properties.
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Last modified: May 25, 2011