- 5 - 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”.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