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true and correct copies of petitioners’ 1996 and 1997 Federal
income tax returns;
(2) Before 1995, Mr. Ward was a partner with Jack Ward in
various partnerships that engaged in video and real property
rentals;
(3) Before 1995, the Wards owned their residence at Reef
Place, the Parkview Rentals, an interest in Parkview Partnership,
an interest in the Video City Partnership, an interest in the
Arctic Building Commercial Partnership, an interest in the Arctic
Video City Partnership, and an interest in an office building;
(4) Beginning in 1995, the Wards formed various trusts and
transferred their partnership and real property interests to the
trusts;
(5) Around 1995, the Wards transferred their residence at
Reef Place to GNI;
(6) Around 1995, the Wards transferred their interest in
Parkview Rentals and the Parkview Partnership to GNI;
(7) GNI paid nothing to acquire the Wards’ residence, their
interest in Parkview Rentals, and their interest in the Parkview
Partnership;
(8) Around 1995, the Wards transferred their interest in the
Video City Partnership to ASI;
(9) ASI paid nothing to acquire the Wards’ interest in the
Video City Partnership;
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Last modified: May 25, 2011