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From its inception in 1989, CMA Capital Group (Cap Group)
was a wholly owned subsidiary of Cap Corp. From its inception
until December 2, 1996, Crispin Koehler Securities (CKS), a
securities broker-dealer, was also a wholly owned subsidiary of
Cap Corp.
In 1989, Crispin and Koehler formed JetFleet Aircraft, LP
(JetFleet I), a California limited partnership that invested in
leased aircraft and related equipment. Crispin, Koehler, and Cap
Group were general partners of JetFleet I. In 1991, Crispin and
Koehler formed JetFleet Aircraft II, LP (JetFleet II), another
California limited partnership that invested in leased aircraft
and related equipment. Crispin, Koehler, Cap Group, and CMA
Capital Group LP were general partners of JetFleet II. CMA
Capital Group LP9 was a California limited partnership that was
formed in 1992. Crispin and Koehler were general partners of CMA
Capital Group LP and PSC Aircraft Leasing was a limited partner
of CMA Capital Group LP. CMA Capital Group LP was dissolved on
May 31, 1994.
The main business location and/or the administrative and
support functions of Cap Corp., Cap Group, CKS, and the JetFleet
I and JetFleet II partnerships were at petitioner’s office in
Burlingame, California. Cap Corp. and its two subsidiaries, Cap
9Not to be confused with CMA Capital Group (Cap Group), the
CMA Capital Corp. (Cap Corp.) subsidiary formed in 1989.
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