Walter L. Medlin - Page 140

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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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