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California. The company, which was family owned, rented
construction equipment, such as dump trucks, skip loaders, and
air compressors, and sold building materials, such as rock, sand,
and cement blocks.
In 1983, petitioner was also a member of the board of
directors of Riverside Thrift & Loan Association, a state-
chartered financial institution in Riverside, California. As a
board member, petitioner received director’s fees in the amount
of $6,320.
In 1983, petitioner had fractional interests in commercial
real estate that produced net rental income. Petitioner also
received fees in the amount of $9,526 for managing one of these
properties.
In 1983, petitioner also had an interest in some orange
groves in southern California. The orange groves produced
minimal income.3
In 1983, petitioner was financially well off and
sophisticated. Without regard to partnership and farm losses,
petitioner’s reported income exceeded $200,000 for that year,
including (but not limited to): (1) Compensation from Wiest
Rentals in the amount of $36,500; interest income in the amount
of $52,991; capital gain (net of the 60 percent deduction under
3 On his Schedule F, Farm Income and Expenses, petitioner
reported a gross profit of $262 and deducted expenses of $7,181,
for a net loss of $6,919.
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