Carl Goudas and Marilyn Goudas - Page 13

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          Pecaris allocated the gain to its three partners in accordance              
          with their interests in profits, as specified in the Pecaris                
          partnership agreement.  Accordingly, Pecaris reported                       
          petitioner’s distributive 25-percent share of the gain from the             
          sale, $827,968, on its Schedule K-1, and that is the amount of              
          the adjusting increase in petitioner's gain as determined in                
          respondent's statutory notice to petitioner.                                
               Coastal and petitioner reported the transactions affecting             
          petitioner’s interest in the Mall as nontaxable transactions on             
          their respective returns for 1988.  The yearend tax balance                 
          sheet, Schedule L of Coastal's 1988 Form 1065, disregarded                  
          petitioner's capital contribution of $700,000 as having any                 
          effect for tax purposes on petitioner's capital account or on               
          Coastal's basis in the Mall, and showed Coastal as having a cost            
          basis in the Mall substantially less than $4.8 million, on the              
          order of what would have been approximately $4.1 million as of              
          the time of the conveyance of the Mall by Pecaris to Coastal.10             

          10The Coastal 1988 yearend Schedule L Tax Balance Sheet and                 
          schedules thereto do not disclose or show any note or other                 
          obligation of Coastal to HGM in respect of the $100,000                     
          commission.  The Coastal balance sheet and Schedule M                       
          Reconciliation of Partners' Capital Accounts show the following:            
                                Schedule L - Balance Sheet                            
          Assets                                                                      
          Cash                                  $74,886    Current liabilities $102,026
          Trade accounts and                                                          
          receivables                          78,159    Mortgages, etc.    4,071,244 
                                                             (continued...)           




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