Raymond Albert Moorefield - Page 2

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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              
               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                    

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