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Sandlake Executive Center (Sandlake), and Sandlake owned an 80-
percent interest in a partnership known as Chancelor Concourse
Joint Venture (CCJV). CCJV had been formed to purchase, develop,
and sell a particular parcel of real property. Around June or
July 1990, the Orange County School Board and Orange County,
Florida, condemned the real property owned by CCJV (CCJV real
property), and OIP received certain cash proceeds (condemnation
proceeds) as a result of that condemnation.
The terms of a document entitled "Warranty Deed", which
bears the date of February 28, 1992, was signed by Mr. Canty as
president of OIP, and was recorded on September 10, 1993 (re-
corded Vero Beach property warranty deed), recite that OIP was
transferring the Vero Beach property to FIIC for $10 and other
valuable consideration.6 That document also recites that $2,520
in document stamps was paid to the State of Florida with respect
to the transfer recited in that document. Based on the amount of
such document stamps, the value of the Vero Beach property for
Florida document stamp purposes was $360,000.
The terms of a document entitled "Assumption of Obligations
Under Promissory Note and Mortgage Deed", which also bears the
date of February 28, 1992, was signed by Mr. Canty as president
of FIIC, and was never recorded, recite that FIIC agreed (1) to
6As discussed above, OIP had purchased the Vero Beach prop-
erty on Dec. 11, 1990. Petitioners claim that OIP acquired that
property on that date as part of a like-kind exchange under sec.
1031.
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