Donald J. and Judith E. Peracchi - Page 4

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          date of transfer, and an adjusted basis of $349,774.06 in the               
          hands of petitioners on that date.  As of that date, the Clinton            
          Way Property was encumbered by a deed of trust in favor of                  
          Standard Insurance Company securing a note (the Standard                    
          Insurance Note) having an unpaid principal balance of                       
          $1,386,654.50.  NAC Corporation did not assume liability under              
          the Standard Insurance Note, on which petitioners remained                  
          personally liable.                                                          
               The second and third of the three parcels of real property             
          which petitioners transferred to NAC Corporation, collectively              
          referred to herein as the Fresno/Herndon Property, had a fair               
          market value of $1,200,000 on December 26, 1989, the date of                
          transfer, and an adjusted basis of $631,632.42 in the hands of              
          petitioners on that date.  As of that date, the Fresno/Herndon              
          Property was encumbered by a deed of trust securing a note (the             
          Bunn & Duran Note) in favor of certain individuals having an                
          unpaid principal balance of $161,558.28.  NAC Corporation did not           
          assume liability under the Bunn & Duran Note, on which                      
          petitioners remained personally liable.  The parties agree,                 
          however, that the Fresno/Herndon Property, when transferred to              
          NAC Corporation, remained "subject to" the Bunn & Duran Note.               
               The following table reflects the computation of the excess             
          of the above-described liabilities over petitioners' combined               






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