-8-
property. Decedent owned the other undivided one-half interest
in that property. The deed of transfer signed by decedent states
that the transfer was made in consideration of love and
affection. Petitioner gave decedent no money for the Putnam
County property.
The Thompson partnership signed an addendum to the contract
on August 1, 1980, after Pacetti assigned it to the partnership.
The addendum stated that, as part of the sale, petitioner agreed
to buy 7,000 cords of timber for $150,000 from the property being
sold to the partnership.
The Thompson partnership bought the 2,283 acres of land on
August 1, 1980, for $700 per acre. Petitioner received no cash
from the downpayment and paid $49,000 of his own money to the
buyers at the closing on the property.
The Thompson partnership sold 4,000 cords of timber from the
Putnam County property to the Lewis Timber Co. after the Thompson
partnership bought the Putnam County property.
The Thompson partnership bought the Putnam County property
for residential development. The Thompson partnership applied
for, but could not get, zoning for residential development except
for the waterfront property released when the partnership bought
3(...continued)
transferred using petitioner's figure of 2,360 acres.
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