Maureen Monsour - Page 8

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          time not disclosed by the record after 1986, petitioner ques-               
          tioned Mr. Monsour about whether Mr. Monsour’s Florida invest-              
          ments were worthwhile, to which he responded that they were.                
          Except for having informed petitioner that he thought his Florida           
          investments were worthwhile, Mr. Monsour did not discuss with               
          petitioner any of the nontax business aspects of Mr. Monsour’s              
               In 1986, Mr. Monsour began to experience tax problems when             
          Congress enacted certain provisions into the Code that in general           
          eliminated the favorable tax treatment that the Code had previ-             
          ously permitted with respect to at least certain of Mr. Monsour’s           
          Florida investments.  Starting in 1986, Mr. Monsour also began to           
          experience certain nontax problems with at least certain of those           
          investments, including those discussed below.                               
               At a time not disclosed by the record, Highlander Properties           
          Enterprises, Inc. (Highlander Properties Enterprises), commenced            
          an action in the Circuit Court of the Twelfth Judicial Circuit in           
          and for Sarasota County, Florida (Florida Circuit Court) against,           
          among others, petitioner and Mr. Monsour (Florida Circuit Court             
          action).  As a result of that action, on July 12, 1993, units 1,            
          2, 4, 5, 6, 201, 202, 203, 204, 205, 401, 402, 403, 404, and 405            
          of the Three Crowns Hotel were sold to Highlander Properties                
          Enterprises in a foreclosure sale.  Thereafter, on a date not               
          disclosed by the record in 1994, petitioner and Mr. Monsour                 

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