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Respondent contends that we should give no weight to the
testimony of Mrs. Beeler, Dakic, Burke, and Gilmore because it
was self-serving and unbelievable. We disagree. We may not
arbitrarily disregard unimpeached, competent, and relevant
testimony. Conti v. Commissioner, 39 F.3d 658, 664 (6th Cir.
1994), affg. 99 T.C. 370 (1992) and T.C. Memo. 1992-614; Loesch &
Green Constr. Co. v. Commissioner, 211 F.2d 210, 212 (6th Cir.
1954), revg. a Memorandum Opinion of this Court. Mrs. Beeler,
Dakic, Burke, and Gilmore testified in a manner fully consistent
with the documents related to the transaction at issue and with
each other's testimony. Respondent produced no evidence to the
contrary.
We conclude that petitioners transferred land and no other
tangible property to the buyers.
2. Whether Petitioners Exchanged Their Mining and
Construction and Demolition Debris Dump Permits
Respondent contends that petitioners exchanged their Pasco
County sand mining and construction and demolition debris dump
permits with the 76.5 acres. We disagree.
The parties to the exchange and their attorneys testified
that petitioners did not exchange their Pasco County permits.
The documents conveying property in the exchange did not list the
permits.
Cynthia Jolly (Jolly) was the Code Enforcement Director for
Pasco County at the time of trial. She was very knowledgeable
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