John Karason - Page 6




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          KCPI.  The purchase agreement between Dr. Karason and Dr. Flom              
          did not mention petitioner’s name, indicate that the medical                
          equipment was assigned to petitioner, or that petitioner was                
          going to purchase the equipment.                                            
          D.   Karason Capital Partners                                               
               Petitioner formed KCP in 1989 with members of his family for           
          the purpose of investing in property.4  Petitioner prepared all             
          of KCP’s Federal partnership tax returns.  According to the                 
          partnership returns, petitioner was a partner from 1989 through             
          1993 and 1996 through 2001,5 and Dr. Karason was a partner in KCP           
          from its formation.6  In 2001, petitioner owned a 70-percent                
          interest in KCP, and Dr. Karason owned the remaining 30 percent.            
               During 2001, KCP’s purported business activities included              
          renting real property and breeding race horses.  KCP’s Form 1040            
          Schedule E, Supplemental Income and Loss, for 2001 reported that            
          the rental properties generated a $31,337 loss, and Form 1040               
          Schedule F, Profit or Loss From Farming, for 2001 reported the              
          horse breeding activities generated a $13,933 loss.  KCP’s                  
          Schedule K-1, Partner’s Share of Income, Credits, Deductions,               


               4 The partnership also went by the names Karason Family                
          Partnership and Karason Family Investment Club.                             
               5 Petitioner did not own a direct partnership interest in              
          KCP in 1994 and 1995.                                                       
               6 From 1990 through 1999, KCP’s partners at various times              
          included petitioner’s mother, father, and various other entities.           
          Petitioner and Dr. Karason were the only partners in 2001.                  





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