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several real properties.
One of the real properties that Markfel had identified as a
desirable investment was a property located at 1020 Church
Street, San Francisco, California. Sometime around the end of
September 1988, the Church Street property was purchased in the
names of Mr. Vulis and Peter Kogan (Mr. Kogan). At a time not
disclosed by credible evidence in the record, petitioner directed
that an unspecified portion of the funds that he had paid Markfel
be invested in the Church Street property. At least during part
of 1991 and 1992 until the date of the sale of the Church Street
property, Mr. Vulis, Mr. Kogan, and petitioner owned certain
interests in that property. The extent of petitioner’s interest
in that property is not disclosed by credible evidence in the
record. As an owner of an interest in the Church Street prop-
erty, petitioner was responsible for paying a certain portion of
any expenditures with respect to that property.
In 1992, the Church Street property was sold. Sometime
thereafter, Mr. Vulis provided certain information with respect
to that sale, which is not disclosed by the record, to Edward
Sutton (Mr. Sutton), the preparer (return preparer) of Form 1040,
U.S. Individual Income Tax Return, that petitioner and Ms.
Brodsky jointly filed (joint return) for 1992.
Sanchez Street Property
During at least 1987, 1988, 1991, and 1992, petitioner, Ms.
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