James O. Jondahl - Page 13

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         Insurance $10,038 in 1990 in satisfaction of the remainder of the            
         purchase price, in accordance with the terms of the sale.                    
         Petitioner deposited the proceeds from the sale in WFIC’s                    
         checking account.  Petitioner did not report any capital gain                
         from the sale to Mr. Ihry on his 1990 individual Federal income              
         tax return.                                                                  
              E.  Lone Tree Manor Apartments                                          
              On April 1, 1987, petitioner purchased Lone Tree Manor                  
         apartment complex from Investors Real Estate Trust (IRET).  IRET             
         held the mortgage on Lone Tree Manor until 1990.  The income and             
         expenses related to the operation of Lone Tree Manor were                    
         reported on petitioner and Lori’s joint Federal income tax                   
         returns for 1987 and 1988.  Lori reported the income and expenses            
         for Lone Tree Manor on her individual 1989 income tax return.  In            
         November 1990, IRET repossessed Lone Tree Manor.  Petitioner did             
         not report any gain resulting from the repossession of Lone Tree             
         Manor on his 1990 Federal income tax return.  WFIC reported                  
         capital gain of $22,028 from the sale of Lone Tree Manor on its              
         1990 Form 1120.                                                              
         II.  Other Expenses                                                          
              Petitioner, Taxman, and WFIC each maintained bank accounts.             
         Petitioner had signatory authority on all these accounts.                    









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