- 40 - 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”.Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
Last modified: May 25, 2011