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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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