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signed the sales contract. Petitioner did not report any income
from this sale on his Form 1040 for 1988.
The record contains two personal financial statements for
petitioner. The first is dated November 15, 1985, and lists as
an asset, East Lake Vista;27 a “160 acre parcel located on East
Lake North of Narcoossee being subdivied [sic] into 5 ac. tracts
and is encumbered by 2 mortgages totaling $386,000.00”. The
listing states: “I own 1/2 interest”, and values that interest
at $560,000, subject to liabilities of $193,000. The second
financial statement is dated June 1, 1988, and lists as an asset,
East Lake Vista; a “100 acre parcel located on East Lake North of
Narcoossee being subdivided into 5 ac. tracts”. That property is
listed under “Miscellaneous Lots & Acreage (Unencumbered)” and is
valued at $400,000.
Mr. Miles’s law firm maintained certain ledger cards,
numbers 70006 through 70008, which are entitled “Walter
Medlin/Reba Smith”, “Medlin Re: Smith, Reba”, and “Medlin,
Walter from Reba L. Smith”, respectively. Those ledger cards
contain the following relevant entries:
27Petitioner testified that East Lake Vista is also known as
the “Narcoossee property” and the “Dan Smith Road property”. The
parties also agree that the property was sometimes called the
“Reba Smith property”.
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