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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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