- 81 - approach in this case, if petitioner sold the Citrus County Property to a willing buyer for its fair market value of $87,000, and then transferred the sale proceeds in partial satisfaction of his personal liability as guarantor, he would have realized $85,156 ($87,000 amount realized minus $1,844 basis). On the facts presented, we hold that petitioner realized $85,156 on the foreclosure sale to Freedom. C. Miscellaneous Items of Schedule C Income FINDINGS OF FACT On February 6, 1985, petitioner deposited $37,500 into his bank account with Freedom Savings & Loan Association. The record contains a check of $37,500 from Orange Valley Real Estate Exchange, Inc., to the order of Metro Realty Association. The spreadsheets that petitioner used to complete his tax returns list this amount under “Sales & Comm”. Petitioner reported this amount as a part of his gross profit from his real estate business on Schedule C of his 1985 return. Petitioner received net commission income of $598 from National Land Commissions in 1986. On July 1, 1985, petitioner deposited checks from Crazy Commandos of $250 for rent from June 15 to 30, 1985, and $500 for rent from July 1 to 31, 1985. Petitioner also deposited $500 of rent from Crazy Commandos into his Freedom account on September 59(...continued) T.C. Memo. 1997-298; Rev. Rul. 90-16, 1990-1 C.B. at 13.Page: Previous 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 Next
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