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purchasers to facilitate its acquisition.46 On October 17, 1978,
the bank sold the Prather Ranch Property to Investors Realty of
Osceola, Inc., Agri-Land Corp., William L. Gibson, as trustee,47
Mr. Prewitt, as trustee, William R. Wright (i.e., petitioner), as
trustee,48 and Marlborough Investors, Inc. At the time of its
purchase, the Prather Ranch Property consisted of 1500-1600 acres
and was generally flat pasture with a creek running through the
property; the property was zoned agricultural.
In 1981, Mr. Gibson sold a portion of the property that he
held in trust to third parties. On June 7, 1985, Mr. Gibson
transferred the remaining property, which we refer to as “parcel
1”, to Mr. Miles, as trustee, for no consideration. Petitioner
was the beneficiary of a 100-percent interest in parcel 1.
In March 1983, Mr. Schoolfield, Max Hagen, and petitioner
entered into an agreement to trade and to purchase certain
parcels of the Prather Ranch Property.49 Pursuant to this
46Mr. Schoolfield was interested in the front piece of the
property, and petitioner was interested in the back piece.
47Petitioner was the beneficiary of the property interest
held in trust by Mr. Gibson.
48Petitioner and Agri-Land Corp. were originally the
beneficiaries of 50-percent interests, respectively, in the
property held in trust by “Mr. Wright” (parcel 3). Agri-Land’s
interest in this parcel subsequently terminated.
49According to petitioner, he ended up with a piece of the
Prather Ranch Property in its southeast corner; Mr. Schoolfield
owned a piece in front of petitioner’s, which had “good access”;
and Mr. Hagen owned a 400-acre piece south of Mr. Schoolfield’s.
(continued...)
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