- 4 - 12 parcels of unimproved real property located in Hernando, Citrus, Volusia, and Marion Counties, Florida (the 12 parcels). Ampel Corporation, Ltd. (Ampel), is a British Virgin Islands corporation. In December 1987, Ampel purchased the 12 parcels from petitioner. Ampel agreed to pay a total of $21 million for the 12 parcels. Petitioner received no cash from Ampel at the time of sale, but he received 12 notes from Ampel, in various amounts, one for each property, evidencing Ampel’s obligation to pay the $21 million purchase price in installments, with interest (the 1987 Ampel notes). The 1987 Ampel notes are similar (at least 11 are; one, inexplicably, is not in evidence), all calling for both interest and principal payments beginning in January 1989. A mortgage secures each note. Petitioner reported the sale of the 12 parcels on the 1987 return. He reported that sale under the installment method of accounting. He reported a selling price of $21 million, an adjusted basis of $6,751,500, commissions and other expenses of sale of $189,365, and no payment in 1987. Ampel did not make the 1989 payments to petitioner called for in the 1987 Ampel notes. Floridama Finance, Ltd. (Floridama), is a British Virgin Islands corporation formed on February 24, 1989. On March 2, 1989, Floridama purchased the 1987 Ampel notes from petitioner. Floridama agreed to pay a total of $19,501,158.56 for the 1987Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011