Thomas C. Sandoval, Jr. and Bobbie J. Sandoval - Page 8

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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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