Marguerite Barrow and William D. Barrow - Page 6

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          commission to petitioner.  None of the Holiday Isle closing                 
          documents show that Dogwood Acres was involved in the                       
          transaction.  Neither petitioner nor Harris told Yost that                  
          petitioner or Dogwood Acres was involved in the Holiday Isle                
          joint venture.                                                              
               Petitioner deposited the $250,000 in his personal checking             
          account on September 22, 1983.  Also on that day, he wrote checks           
          from that account for $100,000 to Dogwood Acres, $75,000 to Saudi           
          Corp. as a loan, and $60,000 to Valparaiso Bank & Trust Co.                 
          Saudi Corp. paid $75,000 to Dogwood Acres in December 1983.                 
          Thus, Dogwood Acres received $100,000 from petitioner and $75,000           
          from Saudi Corp.                                                            
                                     Discussion                                       
          A.   Contentions of the Parties                                             
               Petitioner contends that $175,000 of the $250,000 that he              
          received as a result of the Holiday Isle transaction is income to           
          Dogwood Acres and not to him.  Petitioner contends that the                 
          $175,000 was Dogwood Acres' share under a joint venture agreement           
          that it had with petitioner and Saudi Corp.                                 
               Respondent contends that the $250,000 is gross income to               
          petitioner and that petitioner improperly tried to avoid taxation           
          of the payment by assigning his income to Dogwood Acres.                    
          Respondent contends that petitioner has not shown that a joint              








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