Umit Tarakci - Page 4




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          (3) the construction and operation of a portable “clean room”5              
          facility.  Cilena maintained a business checking account, and               
          petitioner consistently disclosed the existence of Cilena on his            
          Schedule C.  Petitioner never reported any income attributable to           
          the equipment leasing activity.                                             
               In October of 1990, petitioner and Raymond Cotter (Mr.                 
          Cotter) entered into an oral agreement to commence business as              
          equal partners in “Aeternum”, a general partnership formed under            
          the laws of the State of California.  On May 22, 1992, petitioner           
          and Mr. Cotter reduced the partnership agreement to writing and             
          specified that Aeternum had been in existence since October 3,              
          1990.  The purpose of Aeternum was to “engage in the general                
          business of electronic device research and development,                     
          computerized design, applied research, manufacturing and                    
          consulting, and any other business agreed on by the majority of             
          Partners in writing.”  Petitioner and Mr. Cotter were required to           
          contribute services to Aeternum but were not required to                    
          contribute any initial capital.  The partnership agreement                  



               4(...continued)                                                        
          processing equipment, microscopes and measurement systems, a                
          sputter deposition system, photolithography equipment, and                  
          miscellaneous items.                                                        
               5The portable clean room was a relatively small, mobile                
          structure containing equipment designed to conduct research in              
          the semiconductor field.  The temperature inside the structure              
          was precisely controlled and clean-room filtered air was                    
          circulated.                                                                 





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