FRGC Investment, LLC, James P. Mehen, Tax Matters Partner - Page 3




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          Mehen $4,000 per month from August 1997 through June 1998 for               
          marketing services.                                                         
               Petitioner was president of Peyton Community Builders (PCB),           
          a residential and commercial building construction company,                 
          during all relevant times.  Previously, petitioner had been                 
          president and chairman of the Del Webb Commercial Properties                
          Division, a land development company.  In 1987, petitioner was              
          involved in developing Forest Highlands, an upscale golf                    
          community located in the Flagstaff area.                                    
          Subject Property                                                            
               The subject property was 404 acres of undeveloped land with            
          a mix of dry lake bed, steep hillsides, and pine and aspen                  
          forests.  It offered scenic views of the San Francisco Peaks and            
          the city of Flagstaff.  The dry lake was formed by volcanic                 
          activity over 1,000 years ago.                                              
               The property was owned by Cherry Properties, LLC (Cherry).             
          Cherry was owned by Rex and Ruth Maughan, who acquired the                  
          subject property in 1994 from the Resolution Trust Corp.                    
               Ronald Walker (Walker) was Rex Maughan’s real estate broker.           
          As part of his due diligence, in or before 1994, Walker met with            
          the Coconino County planning director and reviewed the 1983                 
          Coconino County Board of Supervisors minutes (1983 minutes).                
          Walker discovered that the subject property was zoned for 1,596             
          residential units, a golf course, a school, and commercial                  






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