Larry L. Beeler and Cynthia J. Beeler - Page 11

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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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