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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
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Last modified: May 25, 2011