- 12 - Florida. He testified that, if he could have sold the 12 parcels in 1987 for $10 million in cash, he would have done so. He testified that he viewed the $21 million, no downpayment price agreed to by Ampel as a “speculative price”. On March 2, 1989, when petitioner sold the 1987 Ampel notes to Floridama, Ampel was in default on those notes. Adding the unpaid, accrued interest to the $21 million principal amount of the 1987 Ampel notes results in an unpaid, total obligation of almost $23.5 million. The Floridama note was in the principal amount of $19.3 million and Floridama paid petitioner cash of $201,159. We do not believe that the 1987 Ampel notes were worth their face amount, nor do we believe that the Floridama note was worth its face amount. The 1987 Ampel notes were eventually exchanged by Floridama to Ampel for the Floridama note (received by Ampel from petitioner), and petitioner ended up with the 1991 Ampel notes, which, as of 1997, had not been paid. Relying principally on petitioner’s testimony, we find, as stated, that the fair market value of the Floridama note, as of March 2, 1989, was $7 million. Making the necessary allocations to interest, petitioner calculates that the amount realized on disposition of the 1987 Ampel notes was $6,448,806, which, given petitioner’s adjusted basis in those notes of $6,940,895, means that petitioner realized a loss of $492,089, on the disposition of the 1987 Ampel notes, and we so find.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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