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return. The only other correspondence sent to the Hendrickses
was a Notice of Final Partnership Administrative Adjustments
(FPAA) mailed to the Hendrickses on February 6, 1989.
On April 20, 1989, Boulder Oil and Gas filed a petition with
the Court in response to the FPAA (Boulder Oil and Gas case).
On October 31, 1997, Mr. Hendricks transferred his jointly
held interest in the remaining condominiums to petitioner. For 2
years before the transfer of his interest in the remaining
condominiums, Mr. Hendricks had been advised by his attorney and
John Angeli (Mr. Angeli), the Hendrickses’ new certified public
accountant, to transfer his interest in the condominiums to
petitioner in order to protect the condominiums from any
creditors of Mr. Hendricks in the substantial farming enterprise
Mr. Hendricks was engaged in at the time. Mr. Hendricks’s actual
intent in making the transfers was to protect the investment in
the condominiums because they constituted the Hendrickses’ only
financial resource for their retirement outside of Social
Security. At the time of the transfer, the Hendrickses
mistakenly believed that they had settled the 1983 tax year and
did not owe any tax liabilities associated with 1983 or any other
years.
The farming enterprise Mr. Hendricks was engaged in at the
time of the transfer to petitioner involved a 10-year lease-
purchase of 12,270 acres of Colorado farmland between him as
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