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General Background
Some of the facts have been stipulated and are so found.
The stipulations of fact, the supplemental stipulations of fact,
and the stipulation of settled issues are incorporated by this
reference. Petitioner resided in Florida at the time he filed
his petition.
Petitioner earned a bachelor’s degree in marketing from the
University of Cincinnati in 1951 and a juris doctor degree from
the University of Michigan in 1956.
Petitioner was the sole stockholder and director of Eureka
Field Nursery, Inc. (Eureka Field Nursery), Tropstock, Inc.
(Tropstock), and Kiddies 50 Corp. Each corporation was involved
in the sale and care of plants.
Petitioner was also the sole shareholder of Farm & Grove,
holding 100 percent of its stock, and was entitled to 100 percent
of the profits or losses of Farm & Grove during the years 1989
through 1993. Farm & Grove, an S corporation, was organized in
1978 to sell real estate.
In March of 1985, petitioner formed a partnership referred
to as the Kiddies-CKE 38 Joint Venture.3 Petitioner and his
three minor children (Brian, Erik, and Kris Tietig) were all
3The association was labeled a joint venture on its Form
1065, U.S. Partnership Return of Income. For Federal income tax
purposes, joint ventures are partnerships. Sec. 7701(a)(2).
Thus, throughout this opinion we refer to it as a partnership.
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