Janet L. Wiest - Page 6




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          section 1202) in the amount of $64,694;4 net rental income in the           
          amount of $33,073; and other income (consisting principally of              
          rental management fees and director’s fees) in the amount of                
          $16,006.  In addition, petitioner had equity interests in: (1) A            
          partnership known as M&W Construction;5 (2) a partnership known             
          as Canyon Crest Lots; (3) a partnership known as The Attic; (4) a           
          partnership known as The Thrift Land Company; (5) a partnership             
          known as Sovereign Land Company; (6) San Nicholas, Ltd. (see                
          infra “E” through “K”); (7) two parcels of commercial real                  
          estate; and (8) an S corporation.                                           
               Prior to 1983, petitioner had an interest in a family-owned            
          ranch.  The ranch, which was located in northern California, and            
          grazed about 250 head of cattle, was operated on a day-to-day               
          basis by petitioner’s father, who lived in the area.  The ranch             
          was sold in November 1980.                                                  
          B.  Petitioner’s Friend and Associate William G. Kellen                     
               William G. Kellen (Mr. Kellen) was petitioner’s friend and             
          business associate.  Like petitioner, Mr. Kellen was a member of            
          the board of directors of Riverside Thrift & Loan Association.              


               4 Petitioner’s capital gain included an installment sale in            
          March 1983 of 69,971 shares of Riverside Thrift & Loan                      
          Association at a gross profit of $265,844.                                  
               5  Petitioner’s share of partnership income from M&W                   
          Construction in 1983 was $6,307.  This income is apparently the             
          basis of petitioner’s testimony that his livelihood in 1983 was             
          based, in part, on “some contracting”.                                      





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