Fred L. Baker and Lisa A. Powers - Page 4

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          Partner's percentage of:                                                    
          Partner           Profit      Loss      Ownership of capital                
          Raymond Staron           45%         45%               45%                  
          George D. Allingham      25%         25%               25%                  
          Fred L. Baker            20%         20%               20%                  
          Bernard Staron           10%         10%               10%                  

          The 1987 Schedule K-1 for petitioner reflected his distributive             
          share of partnership loss from rental real estate activity as               
          $19,532.                                                                    
               Partnership returns were also filed for Bass Associates for            
          the years 1988, 1989, and 1990.  Each of these returns contained            
          Schedules K-1 reflecting the same percentage share of profit,               
          loss, and ownership.  These partnership returns reported losses             
          from rental real estate activity for 1988, 1989, and 1990 in the            
          respective amounts of $108,278, $114,015, and $102,867.2  The               
          Schedules K-1 attached to the partnership returns reported                  
          petitioner's share of the partnership's loss from rental real               
          estate activities for 1988, 1989, and 1990 in the respective                
          amounts of $21,656, $22,803, and $20,573.                                   
               Petitioners did not report any losses attributable to Bass             
          Associates on their 1987, 1988, or 1989 individual income tax               


               2The partnership returns reported gross income and expenses            
          from rental real estate as follows:                                         

          1988      1989       1990                                                   
          Gross income             $66,292    $71,166    $74,266                      
          Total expenses           174,570    185,181    177,133                      




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