Walter L. Medlin - Page 97

                                       - 22 -                                         
          states “In addition, any issues not raised in Petitioner’s Brief            
          are also conceded by Petitioner.”                                           
               A.  Rents Received From Island Living, Inc. in 1988                    
                                  FINDINGS OF FACT                                    
               In 1985, petitioner through Mr. Miles, as trustee, purchased           
          property located in Osceola County, Florida, the “Osceola County            
          Property” (OS-19).  On July 22, 1985, petitioner leased that                
          property to petitioner’s corporation, Island Living, Inc., for              
          $3,000 per month.  Petitioner concedes that he received rents of            
          $6,000 in 1985, $24,000 in 1986, $24,000 in 1987, and $12,000 in            
          1988 from Island Living, Inc.                                               
                                       OPINION                                        
               Petitioner did not address on brief whether he received the            
          additional amount of $12,000 that respondent determined as rent             
          in 1988.  We find that petitioner has conceded this matter.  We             
          find that he received $24,000 of rental income in 1988 and that             
          he is taxable on that amount.  See sec. 61(a)(5).                           
               B.  Schedule C Gains From Property Sales                               
               1.  Florida Fruit Belt Subdivision (OS-06)                             
                                  FINDINGS OF FACT                                    
               On April 11, 1985, petitioner through Mr. Miles, as trustee,           
          sold three lots from the “Florida Fruit Belt Subdivision” located           
          in Osceola County, Florida, to Burl and Louise Mynhier for                  
          $69,000.  Mr. and Mrs. Mynhier paid cash of $33,000 and issued to           






Page:  Previous  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  Next

Last modified: May 25, 2011