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been filed or any Schedules’ K-1 having been issued to petitioner
or Mr. McLaughlin. Petitioner has submitted no evidence of any
partnership records, any partnership agreement, and he has not
provided any discussion regarding the operations of this supposed
partnership. The record shows that petitioner’s and Mr.
McLaughlin’s relationship with respect to the Angel-Royse
Property never rose above mere coownership. Petitioner has not
established that he and Mr. McLaughlin formed a partnership with
respect to the Angel-Royse Property, and we sustain respondent’s
determination that petitioner realized gain on the exchange of
properties.
8. Prather Ranch Property (OR-01)
FINDINGS OF FACT
In 1978, petitioner and Wayne Schoolfield sought to acquire
certain property owned by the Bank of Palm Beach and Trust Co.,
located in Orange County, Florida, which we refer to as the
“Prather Ranch Property”. Petitioner secured a contract with the
bank for the purchase of the property, and he then located other
45(...continued)
in and cut all the trees on the property and start digging out
the dirt”, and that these operations resulted in considerable
environmental problems. The record also contains a letter from
Mr. Miles, in which he complains to petitioner and Mr. McLaughlin
that they had not paid their installments on the 1986 mortgages
associated with the property and that the mortgagees were
threatening foreclosure.
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