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On May 3, 2005, the settlement officer held a telephonic
conference with petitioner’s authorized representative (May 3,
2005 conference). During that conference, the settlement officer
asked petitioner’s authorized representative questions about some
of the answers in petitioner’s March 15, 2005 Form 433-A, includ-
ing whether the $40,000 value shown for each of the real proper-
ties represented petitioner’s one-half interest in each such
property and the purpose for which petitioner had borrowed
$50,000 from his brother. The only question that petitioner’s
authorized representative was able to answer was with respect to
the $40,000 value shown in petitioner’s March 15, 2005 Form 433-
A. In response to that question, petitioner’s authorized repre-
sentative informed the settlement officer that he believed that
the $40,000 shown in that form represented the value of peti-
tioner’s one-half interest in each of the real properties.
Petitioner’s authorized representative told the settlement
officer that he would obtain from petitioner answers to the
remaining questions that the settlement officer asked. Peti-
tioner’s authorized representative also informed the settlement
officer during the May 3, 2005 conference that he was aware of
one pending judgment against petitioner,4 that petitioner had
received $100,000 from his mother to pay personal living ex-
4As discussed below, petitioner’s authorized representative
later advised the settlement officer that the pending judgment
was in the amount of $12,000.
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Last modified: November 10, 2007