- 26 - correct amount of capital gain on the sale of Sipsey Harbor lots and the sale of trucks. Sipsey Harbor Petitioner contends that he sold Sipsey Harbor in one transaction, while respondent contends that the Sipsey Harbor lots were disposed of in several transactions. Sipsey Harbor consisted of 41 lots. In 1988, petitioner issued an undated warranty deed for Sipsey Harbor to Ann Burdick and Tarrie Hyche. Yet on his financial statements dated July 27, 1989 and July 31, 1989, petitioner represented himself as the owner of 30 Sipsey Harbor lots worth $450,000. Thus, despite the warranty deed issued by petitioner to Tarrie Hyche in 1988, petitioner still considered himself the owner of 30 Sipsey Harbor lots in July 1989. In 1989, petitioner was the grantor on deeds to two Sipsey Harbor lots, which were recorded in the Winston County property records. In 1990, petitioner was the grantor on deeds to four Sipsey Harbor lots, which were recorded in the Winston County property records. Thus, rather than disposing of Sipsey Harbor in one transaction, petitioner disposed of his interest in two Sipsey Harbor lots in 1989 and four Sipsey Harbor lots in 1990. No sales are reflected on petitioner’s 1989 or 1990 return, nor is there any evidence to corroborate petitioner’s alleged disposition of petitioner’s entire interest in Sipsey Harbor.Page: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
Last modified: May 25, 2011