- 2 - 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.Page: Previous 1 2 3 4 5 6 7 Next
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