- 65 - 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.Page: Previous 55 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 Next
Last modified: May 25, 2011