Thomas A. and Maria M. Hagman - Page 3




                                        - 3 -                                          
          I.  The MacCoon Note                                                         
                                   FINDINGS OF FACT                                    
               Petitioners Thomas A. and Maria M. Hagman, husband and wife,            
          resided in Thousand Oaks, California, at the time their petition             
          was filed.  Maria M. Hagman is a petitioner in this case because             
          she joined in filing Federal income tax returns with Thomas A.               
          Hagman (Mr. Hagman).  Subsequent references to “petitioner” refer            
          only to Mr. Hagman.  Petitioners’ 1988 and 1989 Federal income               
          tax returns were filed on February 3, 1993, and September 30,                
          1993, respectively.                                                          
               Mr. Hagman was employed as a bank manager for 13 years.  In             
          1974, he left banking to pursue a career investing in real                   
          estate.  In 1978, petitioner became aware of an opportunity to               
          buy a 16-acre parcel of real estate within the city limits of                
          Thousand Oaks, California.  The parcel was available for sale                
          only if the seller could also sell the adjacent property.                    
          Petitioner lent $65,000 to Grant MacCoon (Mr. MacCoon) for the               
          purpose of purchasing the adjacent parcel.  Petitioner and Mr.               
          MacCoon had an agreement that petitioner would receive 25 percent            
          of Mr. MacCoon’s profits on the sale of the adjacent land.  Mr.              
          MacCoon gave petitioner a 10-year unsecured note, bearing 7                  
          percent interest.  The interest and principal were payable at                
          maturity.                                                                    
               In 1979, Mr. MacCoon made a $5,000 principal payment on the             
          note, reducing the amount of the note to $60,000.  The following             
          year, Mr. MacCoon sold the property for a $400,000 profit but did            


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