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determined by respondent. Unless otherwise indicated, all
section references are to the Internal Revenue Code in effect for
the year in issue.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioner resided in California at the time that he filed his
petition.
On or about April 24, 1969, petitioner entered into a
contract with Charles Wright (Wright). The contract granted
petitioner an option to purchase a parcel of real property owned
by Wright. In 1979, Wright was declared legally incompetent. On
or about April 21, 1980, petitioner, as one of several
plaintiffs, commenced a lawsuit in the Superior Court of the
State of California for the County of Los Angeles (the Superior
Court) against Wright entitled R.E. Vine Development, Inc., et
al. v. Charles W. Wright, et al. (Vine Development--suit No. 1).
The causes of action that were the subject of the suit included
specific performance, breach of contract, interference with
contract, quiet title, and declaratory relief. On October 5,
1984, a judgment in favor of petitioner in the amount of
$1,613,450.14 was entered. That judgment was thereafter
appealed.
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