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B & K Variety
From 1977 through 1992, petitioner operated a convenience
store called B&K Variety located in New Haven, Connecticut.
Petitioner operated B&K Variety as a sole proprietorship. B&K
Variety was primarily a cash business for which petitioner
maintained a separate bank account. Petitioners reported income
and expenses for B&K Variety on Schedules C of their Federal
income tax returns for the taxable years 1984, 1985, and 1986.
Route 3 Property
Around October 18, 1984, petitioner agreed to purchase
approximately 67 acres of land, together with improvements and
various items of personal property, located on Route 3 in
Sylvania, Georgia (Route 3 property), for a purchase price of
$148,000. Petitioner deposited $5,000 in cash with John Robinson
of Robinson Real Estate to be applied to the purchase price.
Petitioner purchased a cashier's check at Connecticut
National Bank in Bridgeport, Connecticut, on November 28, 1984,
with $143,000 in cash. The sale of the Route 3 property closed
on December 3, 1984. At the closing, petitioner applied the
$143,000 cashier's check to the purchase price.
Route 21 Property
Around November 7, 1984, petitioner agreed to purchase
approximately 347 acres of land located on Route 21 in Sylvania,
Georgia (Route 21 property), for $150,000. On or about November
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Last modified: May 25, 2011