Thomas E. Johnston and Thomas E. Johnston, Successor in Interest to Shirley L. Johnston, Deceased, et al. - Page 3




                                        - 3 -                                         
          the Court, petitioners thereafter filed an opposition to each of            
          respondent’s motions, and respondent filed responses to                     
          petitioners’ objections.                                                    
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect for the years at            
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
                                     Background                                       
               The information below is based upon examination of the                 
          pleadings, moving papers, responses, and attachments submitted in           
          connection with these cases.  Factual recitations are meant to              
          provide context for our analysis of respondent’s motions and                
          endeavor to set forth matters that would appear not to be in                
          dispute.  They do not, however, constitute findings of fact for a           
          subsequent trial.                                                           
          Estrella Properties, Ltd.                                                   
               Prior to and during the years at issue, Thomas E. Johnston             
          (Mr. Johnston) was involved in the real estate development                  
          business.  As relevant herein, he conducted certain of his real             
          estate activities through his wholly owned corporation, Sea-Aire            
          Properties, Inc. (Sea-Aire).  In the mid-1970s, Mr. Johnston,               
          through Sea-Aire, became involved in Estrella Properties, Ltd.              
          (Estrella), a California limited partnership.  Estrella had been            








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011