-18-
Coastline account, where Kortava's initial wire transfer of
$200,000 was deposited. Petitioners did not have an investment
in Saddle Rock and Martis Landing to the extent of the delinquent
tax payments, because those payments were made with funds
belonging to Coastline, but the other items were paid with
petitioners' personal funds.
On October 29, 1991, petitioners sold Martis Landing for
$225,000 and received their net proceeds, $65,837.62, by check.
Petitioners reported the sale of Martis Landing on Form 4797 on
their 1991 return, reporting $13,958 of selling expenses and
$10,312 of gain. Coastline was not a party to the sale of Martis
Landing.
On January 1, 1992, Saddle Rock was sold to Gregory P.
Moeller (Moeller) for $850,000. A Long Form Land Contract
between Coastline, as vendor, and Moeller, as vendee, for the
sale of Saddle Rock was not recorded until November 18, 1994.
Petitioners' and Moeller's signatures on the contract were not
acknowledged before a notary public until November 1994.
Kortava emigrated from Russia in March 1992 and lived in
California for the remainder of 1992.
In 1994, Kortava hired an attorney to assist him in
determining the ownership of Martis Landing and Saddle Rock.
Because of title reports provided by the attorney and a real
estate agency, Kortava believed that petitioners, not Coastline,
owned the properties.
Page: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 NextLast modified: May 25, 2011