- 4 - By 1994, Angelo owned 77.86 percent of Stockton/Elsie, and petitioner owned the remaining 22.14-percent interest. Angelo attempted to sell Stockton/Elsie in 1985; the sale, however, did not occur because the prospective purchaser learned that Stockton/Elsie would need to be cleaned up due to contamination. In 1987 and 1988, Angelo received reports which confirmed contamination in Stockton/Elsie’s soil and groundwater. On March 17, 1992, Angelo filed a lawsuit against several oil companies, including Phillips Petroleum, former owners and tenants, and insurance companies alleging that they were responsible for the cleanup costs. In 1993, the California Regional Water Quality Control Board issued a cleanup and abatement order on Stockton/Elsie to certain past and present owners, including Angelo. Petitioner deducted his share (i.e., 22.14 percent) of these toxic cleanup expenses on his 1993 and 1994 tax returns, and respondent allowed these expenses. Angelo advanced these expenses to petitioner. By 1995, petitioner had not paid these amounts back to Angelo. On August 1, 1995, due to his health problems, financial problems, and fear of potential lawsuits regarding the contamination of Stockton/Elsie, petitioner deeded his entire interest in this property to Angelo. This deed was recorded on January 21, 2000. The deed indicated that there was no value to Stockton/Elsie.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