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agreement, on April 22, 1982, Agri-Land conveyed its portion
(parcel 2) of the Prather Ranch Property to its shareholder, Mr.
Schoolfield, as trustee. On May 10, 1983, Mr. Schoolfield sold
parcel 2 to Mr. Hagen, as trustee, and Mr. Hagen, in turn, sold
it to Mr. Miles, as trustee, for $356,400. Petitioner was the
sole beneficiary of parcel 2. On May 10, 1983, Mr. Wright, as
trustee, conveyed parcel 3 to Mr. Miles, as trustee.
On September 5, 1986, Mr. Miles, as trustee, entered into a
contract with Maury L. Carter to sell parcels 1, 2, and 3 for
$1,731,000. Mr. Carter never saw an advertisement concerning the
sale of this property, and Mr. Carter initiated the sale
discussions with Mr. Miles. Pursuant to this contract, Mr.
49(...continued)
Petitioner testified that Mr. Schoolfield was interested in
purchasing Mr. Hagen’s piece, and according to petitioner:
And as part of an accommodation for him to buy the
Hagen piece, I was going to buy his piece that was next
to my portion of this 1,500 acres. So that would leave
me with Wayne’s piece and my piece, but to accomplish
that--I didn’t have the cash to give Wayne for it--so
we went, both jointly, went and sat down and worked out
a deal with Mr. Hagen.
And the end result of the deal was that Mr. Hagen
would, out of his 400 acres, would trade 240 acres, I
believe it was, with Wayne. So he and Wayne did a
trade of 240 acres. That meant that Hagen owned the
240 acres next to my piece and, at the same time, then
Wayne purchased the remaining portion of the 400 acres
from Mr. Hagen that was down in Osceola County. The
240 acres that Mr. Hagen now owns, up in Orange County,
next to my piece, I purchased from him. I added to my
holding by purchasing the property from Mr. Hagen, that
he’d acquired from Wayne.
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