Larry L. Beeler and Cynthia J. Beeler - Page 16

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            permits.  Respondent contends that this shows that petitioners                              
            transferred the permits.  We disagree.  The $1.2 million exchange                           
            value is consistent with Catlett's appraisal of the 76.5 acres                              
            because it was contingent on issuance by Pasco County of the                                
            needed permits to the buyers, not because petitioners transferred                           
            their permits to the buyers.  The effect on the value of the land                           
            of a seller having Pasco County permits is analogous to the                                 
            effect of receipt of a favorable zoning classification.  The                                
            existence of both depends on governmental action.  Both can add                             
            value to the land.  A new buyer may expect that zoning will not                             
            change and may pay more for property because of that expectancy.                            
            Similarly, a buyer of land, the seller of which has a Pasco                                 
            County permit, may expect that his or her application for a new                             
            permit will be approved, and may pay more for the land because of                           
            that expectancy.  However, a seller cannot sell either a permit                             
            or a zoning classification.                                                                 
                  We conclude that petitioners did not sell their Pasco County                          
                  3.    Whether Petitioners Conveyed Goodwill or Going-Concern                          
                  Respondent contends that petitioners transferred $37,000 of                           
            goodwill or going-concern value with the 76.5 acres.  Respondent                            
            points out that petitioners called their sand business the                                  
            "Sunset Sand Mine," and the buyers formed a corporation named                               
            "Sunset Sand Mine, Inc."  Respondent contends this shows that                               

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