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Church Street Property
From 1988 through at least 1992, Mr. Vulis, who at the time
of the further trial in this case was a licensed real estate
broker in the State of California, was the broker in charge of
Markfel Property Management and Investment Corporation (Markfel).
In general, during those years, Markfel served as a real estate
investment vehicle for various individuals who wanted to invest
in certain real properties. As such, Markfel identified a
particular real property as a desirable investment, collected
funds from those individuals who were interested in investing in
that real property, and purchased that real property in the names
of those interested individuals, and not in its own name. Any
individual who chose to invest through Markfel in a particular
real property was responsible for any expenditures with respect
to that real property in proportion to such individual’s invest-
ment interest therein.
At times that are not disclosed by credible evidence in the
record, petitioner paid Markfel amounts of money that are not
disclosed by credible evidence in the record, which were to be
used to invest in certain real properties, to increase his
respective investment interests in such properties, and/or to pay
his proportionate share of any respective expenditures with
respect to such interests. Over the course of his dealings with
Markfel, petitioner allocated the funds that he paid Markfel to
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