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FINDINGS OF FACT

Some of the facts have been stipulated and are found

accordingly.

The

stipulation

of

facts,

the

supplemental

stipulation of facts, and the exhibits submitted therewith are

incorporated herein by this reference.

Petitioner and his wife, Magdalena Frances Wood5

(Mrs.

Wood), resided in Orlando

, Florida, when the petitions in these

cases were filed.

Petitioner graduate

d from West Point in

1960 and served in

the military until 1977.

In 1967 while he wa

s in Florida

attending the Air Ground

Operations School at

Eglin Air Force

Base, petitioner and othe

r officers became sh

areholders of

Miracle Strip Parkway Rea

lty, Inc. (MSPR, Inc

.), a corporation

organized for the purpose

of buying land to b

e divided into lots.

Approximately 20 persons

invested in MSPR, In

c.

At

some

time

before the years at issue

, MSPR, Inc., conver

ted to a limited

partnership and thereafte

r was known as Mirac

le Strip Parkway

Realty, Ltd. (MSPR, Ltd.)

.

Petitioner

was

a

limited partner of

MSPR,

Ltd.

Over

the

year

s, MSPR, Ltd., purch

ased and sold

5Magdalena Frances Wood did not appear at the trial in these

cases and did not execute the stipulation of facts or the

supplemental

stipulation

of

facts.

Respondent

filed

a

motion

to

dismiss the cases with respect

to Mrs. Wood for failure to

properly prosecute.

will

dismiss

these

The

cases

Court as to

will her.

grant respondent’s See Rule 123(b).

motion

and

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