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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