William R.Tinnerman - Page 3

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                                     Background                                       
               Some of the facts and certain exhibits have been stipulated.           
          The parties’ stipulations of fact are incorporated herein by                
          reference and are found as facts in the instant case.                       
          Petitioner resided in St. Augustine, Florida, at the time the               
          petitions were filed in the instant cases.                                  
               Petitioner graduated from the University of Colorado in 1972           
          with a business degree, majoring in finance and minoring in                 
          economics.  Petitioner is a licensed commercial real estate                 
          broker and has commercial real estate management experience.                
               Petitioner failed to file federal income tax returns, make             
          estimated payments, or pay the tax due for his 1999 through 2002            
          taxable years.  During that time, petitioner was the sole                   
          shareholder and president of St. Augustine Self Storage, Inc.               
          (company), an S corporation incorporated in 1986.  When                     
          incorporated, the company had three shareholders, including                 
          petitioner.                                                                 
               The company owns property located at 5 Willard Drive, St.              
          Augustine, Florida (property).  On August 6, 1986, the company              
          executed a note in the amount of $1,225,000 (note) and, to secure           
          the note, a mortgage encumbering the property.  Petitioner did              
          not provide any evidence that he is or has ever been personally             
          liable to pay the note.                                                     







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Last modified: May 25, 2011