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          general partners of MHR Properties, canceled MHR Properties’ St.            
          Clair property interests as early as July 6, 1991, and no later             
          than July 26, 1991; (2) that cancellation was separate from the             
          final exchange transaction that took place on August 1, 1991; and           
          (3) petitioners did not expect to, were not entitled to, and did            
          not receive any quid pro quo from the University in return for              
          the cancellation of those property interests.  Based on our                 
          examination of the entire record in this case, we reject all of             
          those contentions.                                                          
               We consider first petitioners’ contention that the cancella-           
          tion of MHR Properties’ St. Clair property interests occurred as            
          early as July 6, 1991, and no later than July 26, 1991.  To                 
          support that contention, petitioners rely on the July 6 document            
          and the July 22 document.  As for the July 6 document on which              
          petitioners rely, that document was prepared in anticipation of             
          finalizing and closing the exchange transaction to which the                
          University, Mr. Signom, and Mr. Felman had tentatively agreed and           
          related only to MHR Properties’ purchase option and not to MHR              
          Properties’ leasehold interest.  Moreover, the July 6 document              
          stated that Mr. Signom, instead of MHR Properties and/or Mr.                
          Signom and Ms. Signom as the general partners of that partner-              
          ship, was the grantor to the University of MHR Properties’                  
          purchase option.  In addition, Mr. Signom signed the July 6                 
          document in his individual capacity and not as a general partner            
          or otherwise as a representative of MHR Properties.  The signa-             
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