- 6 - 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 jointPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011