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petitioner (1) 1,000 shares of stock in The Masa Land Corp. (Masa
Land), a Florida corporation, and (2) a parcel of real property
located in Collier County, Florida (the Marco Beach lot).
Holland Spring agreed to pay a total of $4 million for the Masa
Land shares, with $200,000 to be paid immediately, in cash, and
the balance ($3.8 million) evidenced by a note and due in two
annual installments, in December 1989 and 1990, respectively.
Holland Spring agreed to pay $2,350,000 for the Marco Beach lot,
that amount evidenced by a note due in June 1990. Petitioner
reported both sales on the 1987 return using the installment
method of accounting.
In 1988, Holland Spring purchased from petitioner
(1) 100 shares of Samajo Investment Corp. (Samajo), a Florida
corporation, (2) 1,000 shares of Daytonapa Corp. (Daytonapa), a
Florida corporation, and (3) a parcel of real property located in
Spring Hill, Florida (the Spring Hill lot). Holland Spring
agreed to pay a total of $840,000 for the Samajo shares, with
$84,000 evidenced by a note due in 90 days and the balance
($756,000) evidenced by a second note due in 18 months. Holland
Spring agreed to pay a total of $1.7 million for the Daytonapa
shares, with $170,000 to be paid immediately, in cash, and the
balance ($1,530,000) evidenced by a note and due in 6 years.
Holland Spring agreed to pay a total of $195,000 for the Spring
Hill lot, with $50,000 to be paid immediately, in cash, and the
balance ($145,000) evidenced by a note due in the future.
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