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7. Arrowhead Lakes Subdivision (OR-2), Angel-Royse
Property (OS-39)
FINDINGS OF FACT
In 1974, Roger McLaughlin, as trustee, purchased Lots 26,
27, and 28 in the Arrowhead Lakes Subdivision (OR-2), which was
located in Orange County, Florida. In 1977, Mr. McLaughlin
conveyed those lots to Ms. Allen, as trustee, for no
consideration. In 1979, Ms. Allen conveyed those same lots to
Mr. Miles, as trustee, for no consideration. Petitioner owned
Lots 26, 27, and 28 in the Arrowhead Lakes Subdivision;
petitioner was the 100-percent beneficiary of the lots held in
trust by Mr. Miles.
In 1983, Mr. Miles, as trustee, purchased 40 acres of a
certain real property in Osceola County, Florida. On January 31,
1983, Mr. Miles, as trustee, issued a mortgage deed (purchase
money note and first mortgage) of $70,200 with respect to this
purchase. On February 24, 1983, Mr. Miles, as trustee, issued to
Mr. McLaughlin a mortgage deed (purchase money note and second
mortgage) of $30,500, which related to the 40-acre purchase. On
March 25, 1983, petitioner entered into a contract to purchase an
additional 34 acres for $102,000. Mr. Miles, as trustee, issued
a mortgage deed of $73,000 for part of the purchase price. The
34 acres were conveyed to Mr. Miles, as trustee, on October 26,
1983. Petitioner and Mr. McLaughlin were equal beneficiaries in
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