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petitioner held an ownership interest in East Lake Vista at the
time of the sales in 1986 and 1988.
First, petitioner’s financial statements dated November 15,
1985, and June 1, 1988, show that he owned at least a 50-percent
interest in East Lake Vista at some point before the sales that
occurred in 1986 and 1988. Petitioner contends that the November
15, 1985, financial statement is not inconsistent with his
testimony and Dr. Gant’s testimony that he was to originally own
a 50-percent interest in East Lake Vista, which subsequently
changed to no interest. Petitioner has not presented any
evidence to establish when his and Dr. Gant’s original
understanding supposedly changed; however, if it did change, we
assume the change would have occurred either before or shortly
after May 1, 1984, when Dr. Gant purportedly “put up all the
money”, the $125,000 cash portion of the purchase price.29 The
financial statement is dated November 15, 1985, a full year and a
half after the purchase of East Lake Vista. Petitioner offers no
explanation why he continued to represent himself as owning a 50-
percent interest in November 1985, if, in fact, he owned no
interest after Dr. Gant put up all the cash in May 1984.
Petitioner also contends that the June 1, 1988, financial
statement cannot be relied upon since it incorrectly shows that
29Dr. Gant testified that he could not recall when the
parties original understanding changed, but he suggested that it
might have been in 1984.
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