Walter L. Medlin - Page 156

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          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.                    




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