Walter L. Medlin - Page 120

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          he owned 100 percent of East Lake Vista and that the property               
          consisted of 100 acres when, in fact, it consisted of 84 acres.             
          We do not agree that these purported inaccuracies cause the June            
          1, 1988, financial statement to lose its persuasive value.  The             
          financial statement was prepared by or for petitioner, and                  
          petitioner does not explain why those inaccuracies were reflected           
          on his financial statement, and why they invariably suggest that            
          he held no interest in East Lake Vista in 1988.  At the very                
          least, the June 1, 1988, financial statement shows that                     
          petitioner perceived himself to own at least some interest in               
          East Lake Vista in 1988 and that he intended other persons who              
          might rely on the financial statement to recognize that                     
          ownership.                                                                  
               The road construction guaranty also indicates that                     
          petitioner had an ownership interest in East Lake Vista.                    
          Petitioner, Mr. Miles, and Dr. Gant executed the guaranty on                
          December 16, 1986, the same date as the sale of the 31.50 acres             
          of East Lake Vista to Mr. Pope.  And, it specifically refers to a           
          contract for the sale of 31.50 acres that Mr. Miles and Mr. Pope            
          entered into on May 2, 1986.  Petitioner argues that this                   
          guaranty originated in petitioner’s “working relationship” with             
          Dr. Gant and did not arise from any ownership interest in the               
          property.  However, petitioner did not present any evidence or              
          testimony to suggest that he was compensated for his real estate            






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