- 6 - In August 1991, petitioner sold the Ranch for $200,000, taking a promissory note for $150,000 and the remainder in cash.1 In October 1992, petitioner assigned this promissory note to a bank for $167,342.82 cash. The Note In May 1992, Youngs was preparing petitioner's 1991 tax return. When attempting to calculate petitioner's gain or loss on the sale of the Ranch, she realized there was no note with respect to the transfer of the Ranch. She raised this point with Eagleson, who said he would prepare a note. In May 1992, Eagleson prepared a promissory note (the Note) with respect to the transfer, and in June 1992, petitioner executed it. The date appearing in the top right corner of the Note executed in June of 1992 was July 2, 1990, which was the date of the transfer of the Ranch. The Note listed the Ranch as security, stating that "payment of this note is secured by that tract of land [i.e., the Ranch] * * * more fully described in the Deed executed on this date, July 2, 1990." There was no date next to petitioner's signature at the end of the Note. The Note called for annual payments beginning July 2, 1992. The Audit Guerra next became significantly involved with the details of the transfer of the Ranch in July 1993, when an audit of Paz 1 Settlement expenses were $13,873.70 and taxes were $1,568.32, so petitioner received net cash of $34,557.98.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011