- 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 NextLast modified: May 25, 2011