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Vero Beach property. Nor was any real estate tax paid as of
October 4, 1994, on the Vero Beach property for any of the years
1990, 1991, 1992, and 1993.
During the examination in 1993 by respondent of petitioners'
consolidated returns for the years at issue, Mr. Canty informed
respondent's examining agent that no replacement property had yet
been purchased with respect to the condemnation proceeds that OIP
received as a result of the condemnation of the CCJV real prop-
erty.
Around October 4, 1994, CCC, one of FIIC's subsidiaries
which was engaged in auto sales during the years at issue, used
the Vero Beach property as collateral with respect to a loan that
it was seeking from the Bank.
In December 1994, Mr. Canty, as president of OIP and IRF,
contracted to have an appraisal done of the 174.5-acre Vero Beach
property and approximately 54 acres of land adjacent to that
property consisting of three parcels (54-acre real property).
The property appraised had approximately 1� miles of waterfront
on the Indian River and approximately 2,000 feet of frontage on
U.S. Highway 1. In a report dated December 15, 1994, the ap-
praiser concluded that the highest and best use for the property
appraised was "future residential development or as an alterna-
tive highest and best use as [sic] for conservation." In de-
scribing the 54-acre real property, the appraiser stated:
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