- 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 toPage: 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