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interest in East Lake Vista. Although Dr. Gant testified that he
did not put up any additional cash after his initial $125,000,
the ledger cards show that $62,867.16 was received from “George
Gant” on May 2, 1984. Further, Dr. Gant testified that he was
the only cash person in the deal; however, the ledger cards show
that $62,873.61 was received on May 2, 1984, from the Medlin/Gant
ledger card.31 Also, the ledger cards show that matching
deposits of $61,646.52 were received on May 14, 1985, from the
Medlin/Tai card. Since petitioner and Dr. Gant each owned a 50-
percent interest in the Tai Property, we assume that petitioner
contributed at least $61,646.52 with respect to East Lake Vista.
The ledger cards also show disbursements to petitioner’s
general ledger card. Moreover, the pattern of duplicate
disbursements shortly after the 1986 and 1988 sales to ledger
cards in which petitioner and Dr. Gant presumably held equal
interests certainly supports respondent’s position that
petitioner and Dr. Gant each owned a 50-percent interest in East
Lake Vista. Petitioner, on the other hand, argues that his and
Dr. Gant’s testimony shows that any amounts he received from the
1986 and 1988 sales were received as loans from Dr. Gant. We
disagree.
31According to petitioner, the Medlin/Gant ledger card
represents “an account in which both Medlin and Gant have an
interest.”
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