- 3 -
in Florida in 1989. Petitioner received, held, and invested
money from foreign investors to finance his real estate
development activity. Investors wired money to petitioner's bank
accounts. He controlled these funds.
At times during 1989, petitioner received money from his
foreign investors before he needed it for the real estate
developments. On several occasions, petitioner used money from
these funds for his personal investments, such as real estate
projects other than those in which the foreign investors were
participating. For example, petitioner used $40,000 from World
Golf & Tennis for a personal investment in a salmon fishery in
Iceland around November 1989.1
During 1989, petitioner borrowed $40,000 from Gilbert Amman.
He repaid those funds in 1989 from the proceeds of the sale of
property at 2171 Rockledge Drive (Rockledge Drive property),
Rockledge, Florida.2
During 1989, petitioner received $934,183 and disbursed
$1,245,625 that did not relate to his investor-funded projects.
He received no gifts or inheritances in 1989.
1 Petitioner concedes that the source of the funds for his
Iceland investment was taxable.
2 Respondent concedes that petitioner is not taxable on this
$40,000.
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