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profitable automobile and truck dealership. In July 1983,
petitioner sold his ownership interest in the dealership and
later became executive vice president of Monitor Dynamics, a
corporation specializing in electronic security systems for both
civilian and military use.
During the year in issue, petitioner Marie M. Finazzo was
employed by the Fontana Unified School District as secretary for
the budget commission.
In 1983, petitioner was financially well off and
sophisticated. For that year, he received compensation from
Midway Honda-GMC, Inc. in the amount of $170,085, gain from the
sale of stock in the dealership in the amount of $245,160, and
interest in the amount of $8,445. In addition, petitioner had
equity interests in: (1) A partnership known as Fontana Bancorp
Development; (2) a partnership known as Carousel Video; (3) San
Nicholas Research, Ltd. (see infra “C” through “F”); and (4) an S
corporation known as Classic Touch, Inc., that manufactured
convertible tops for automobiles in Palm Springs, California.
B. Petitioner’s Friend and Associate William G. Kellen
William G. Kellen (Mr. Kellen) was petitioner’s close
personal friend and business associate.
Mr. Kellen was a general partner and tax matters partner of
four limited jojoba partnerships: Utah Jojoba Research, Ltd.
(Utah Jojoba); Blythe Jojoba I Research, Ltd. (Blythe Jojoba I);
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