- 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 untilPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011