Leonard Ray Blanton and Betty Blanton - Page 13

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            1040X, reporting the $38,334.50 as the gross sales price received                           
            on disposition of the interest in South Texas Drilling.                                     
            Issue 1. Whether Income Petitioner Reported as a Sale of a                                  
            Partnership Interest Was Really Ordinary Income in the Form of a                            
            $15,000 Finder's Fee Paid to Petitioner for Using His Influence                             
            to Assist Jack Ham in Procuring a Construction Loan.                                        
                  Respondent determined that petitioners received income in                             
            1978 of $38,334.50, consisting of a $15,000 finder's fee for                                
            assisting Jack Ham in procuring a construction loan and a                                   
            $23,334.50 fee for assisting Jack Ham in procuring a liquor                                 
            license.  Petitioner asserts that he never had any agreement                                
            with, nor did he receive any fees from the Hams during the                                  
            taxable year in issue.  Petitioner admits that he received                                  
            $38,334.50 in 1978, but asserts that such income was from the                               
            sale of his partnership interest in South Texas Drilling.                                   
            Petitioner concedes that although the transaction was                                       
            inadvertently omitted from his original 1978 joint Federal income                           
            tax return, the sale was properly reported on a timely filed                                
            amended return.                                                                             
                  Based on the entire record and for the reasons discussed                              
            herein, we find that Jack Ham paid petitioner a $15,000 finder's                            
            fee for petitioner's assistance in procuring a $2.5 million                                 
            construction loan for the Hams.                                                             

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