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partnership interest in 1993, and his letter dated April 11 of
that year to Mr. Hunter expressly manifested his intent to do so.
According to respondent, petitioner “had neither the intent
to abandon the interest in Onex Farms, nor did * * * [he]
affirmatively act to abandon the property by walking away from
* * * [his] interest and having nothing more to do with the
property”. Before addressing the dispute between the parties on
these points, we think it is appropriate first to comment on the
dispute between petitioner and Dr. Chambers regarding the
distribution of assets upon the liquidation of Archimedes.
If we ignore the various entities involved, it is fair to
conclude from petitioner’s presentation at trial that Dr.
Chambers considered himself and petitioner to be equal owners of
Onex Farms, which held title to the Georgia farm. Nothing in the
record suggests that Dr. Chambers objected to any other aspect of
the Archimedes liquidation, or that Onex Farms owned any other
property of significant interest to Dr. Chambers. Upon the
liquidation of Archimedes, petitioner’s ownership interest in
Onex Farms, and, more importantly, his right to its assets upon
liquidation, increased. This increase meant that petitioner’s
total interest in Onex Farms (40 percent directly and 20 percent
indirectly through Lever) exceeded Dr. Chambers’s total interest
in Onex Farms. From petitioner’s presentation at trial, it is
clear that this situation was not acceptable to Dr. Chambers.
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