- 60 -
Angel-Royse Property to Michael D. Johnson, as trustee.
Petitioner was the 100-percent beneficiary of the Angel-Royse
Property held in trust. Petitioner did not report any income
from the exchange on a Form 1040 for the tax years at issue.
On June 9, 1987, a final judgment was entered by the Circuit
Court of the Ninth Judicial Circuit of Osceola County, Florida,
in the case of South Fla. Water Mgmt. Dist. v. Walter Medlin,
Steven Miles, Tr., and Robert Adkins, Case No. 85-943. The
judgment was entered into pursuant to a stipulation for consent
decree, which requires petitioner and Mr. Adkins to restore the
Angel-Royse Property and to plant cypress trees. The consent
decree enjoins petitioner and Mr. Adkins from further excavation
or dumping activities on the property.
The record contains no partnership tax returns or Schedules
K-1, Partner’s Share of Income, Credits, Deductions, etc., and
there is no evidence that any such returns or schedules were
filed or distributed.
OPINION
Respondent determined that the value of the 74 acres of the
Angel-Royse Property was $312,600, the value which was assessed
by Osceola County for the two parcels of acreage.39 Respondent
determined that Mr. McLaughlin’s interest had a fair market value
39Osceola County assessed a value of $180,000 for the 40
acres acquired in early 1983 and assessed a value of $132,600 for
the 34 acres acquired on Oct. 26, 1983.
Page: Previous 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 NextLast modified: May 25, 2011