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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
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