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rental properties. Petitioners identified the acquired
properties within 45 days of October 16, 1991. They received
title to the acquired properties within 180 days of October 16,
1991. The acquired property was real property held for
productive use in a trade or business or for investment.
4. Permits for the Buyers
Burke obtained new permits from Pasco County for the buyers
to operate a sand mine and a construction and demolition debris
dump at the 76.5 acres. He obtained all of the permits that the
buyers would need to operate a construction and demolition debris
dump, including permits from the Florida Department of Natural
Resources. The buyers paid more than $100,000 to their
attorneys, engineers, and to Pasco County to obtain the permits.
The buyers gave sand away from the 76.5 acres.
The buyers incorporated their business as Sunset Sand Mine,
Inc. and transferred the 76.5 acres to it.
E. Pasco Lakes, Inc.
In 1989, Larry Gilford (Gilford) owned 50 percent of the
stock of Pasco Lakes, Inc. (Pasco Lakes). In September 1989,
Pasco Lakes paid $675,000 for vacant land zoned for agricultural
use. Pasco Lakes obtained permits to mine sand from the land.
Gilford sold the stock of Pasco Lakes to Environmental Capital
Holdings, Inc. (Environmental) on September 19, 1991.
Environmental bought stock instead of the land because it wanted
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