Thomas F. Hale - Page 5




                                        - 4 -                                         

          to the property.  At trial, petitioner presented several                    
          receipts, invoices, and contracts purporting to relate to                   
          improvements to the property, which petitioner contended                    
          substantiated $9,158 for improvements.  Thus, petitioner took the           
          position at trial that his adjusted basis in the property was               
          $29,158.  For the reasons stated hereinafter, the Court need not            
          address whether the documentation establishes the $9,158 claimed            
          by petitioner for these improvements.                                       
               Following his 1989 acquisition of the property, petitioner             
          and his wife divorced.  In April 1993, petitioner's former spouse           
          executed a quitclaim deed in favor of petitioner for her interest           
          in the property.  Also, during 1993, petitioner entered into a              
          transaction with an individual, Peter Walker Burns (Mr. Burns),             
          in which petitioner conveyed the subject property to Mr. Burns              
          for what petitioner testified was payment of an indebtedness that           
          petitioner owed to Mr. Burns, an attorney, for certain legal                
          services Mr. Burns had provided to petitioner.  However,                    
          petitioner contends that he was given an option to repurchase the           
          property from Mr. Burns.  Although an option contract or                    
          agreement was never prepared or executed by petitioner and Mr.              
          Burns, petitioner executed a promissory note dated October 6,               
          1993, in favor of Mr. Burns in the principal amount of $21,000              
          bearing 8.5 percent per annum interest and payable in monthly               
          installments of $206.80 on the sixth day of each month until                





Page:  Previous  1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011