Walter L. Medlin - Page 127

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          petitioner and Dr. Gant each owned a 50-percent interest.  It is            
          also consistent with their respective interests in another piece            
          of property, the Tai Property.                                              
               We hold that petitioner owned a 50-percent interest in East            
          Lake Vista, and we sustain respondent’s determination that                  
          petitioner realized 50 percent of the gains from the sales in               
          1986 and 1988.                                                              
               6.  Grissom Parcels (OS 1.3)                                           
                                  FINDINGS OF FACT                                    
               On April 15, 1985, petitioner purchased three parcels                  
          (parcels 1, 2, 3) of real property in Osceola County, Florida,              
          which we refer to as the “Grissom Parcels”, for $47,000.  Parcel            
          1 is fronted by U.S. Highway 192, and it borders another road,              
          Rivers Road, on one side.  Parcels 2 and 3 do not border U.S.               
          Highway 192, are separated from parcel 1 by Rivers Road and                 
          several smaller tracts of property, and border a road referred to           
          as “County Road”.  The relative sizes of the parcels are similar,           
          although the dimensions differ.                                             
               On November 5, 1985, petitioner transferred the parcels to             
          Ms. Allen, as trustee, for no consideration.  Petitioner was the            
          sole beneficiary of the parcels conveyed to Ms. Allen.  On                  
          October 22, 1986, petitioner, through Ms. Allen, sold parcel 1              
          for $40,000.                                                                








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