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We found as a fact that Coastline was not a party to the
sale of Martis Landing. Furthermore, petitioners reported the
sale of Martis Landing on their 1991 personal return. The
proceeds of the sale of Martis Landing were deposited into
petitioner's personal account, California Federal account number
6130. No evidence has been presented that Coastline was an owner
of Martis Landing or that Coastline received the proceeds from
the sale of Martis Landing. Petitioners never effectuated a
transfer of Martis Landing to Coastline; thus, no portion of the
money transferred from Coastline's account was in payment for
petitioner's interest in Martis Landing.
Petitioners claim that they transferred Saddle Rock to
Coastline and that Coastline then sold Saddle Rock to Moeller.
Petitioners rely on certain documents, including the following:
(1) A Long Form Security (Installment) Land Contract with Power
of Sale between petitioners, as vendors, and Coastline, as
vendee, notarized on June 21, 1991, and recorded on November 18,
1994; (2) a Grant Deed from petitioners to Coastline dated "as of
January 1, 1992" and notarized on November 17, 1994, and filed on
November 18, 1994; (3) a Long Form Security (Installment) Land
Contract with Power of Sale between Coastline, as vendor, and
Moeller, as vendee, dated January 1, 1992, and recorded on
November 18, 1994; and (4) a Notice of Supplemental Assessment
from the Orange County Assessor showing Coastline as owner of
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