Fred L. Baker and Lisa A. Powers - Page 7

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               STATEMENT 7 - GAINS AND LOSSES FROM SALE OF ASSETS                     
               BASS ASSOCIATES                                                        
               SECTION 1231 GAINS AND LOSSES                                          
                    PTRSHP INTEREST - BASS                                            
                    DATE ACQUIRED 01/01/87  DATE SOLD 12/30/90                        
               GROSS SALES PRICE                             120,000                  
               COST OR OTHER BASIS            185,316                                 
               ADJUSTMENTS TO BASIS                 0                                 
               ADJUSTED BASIS                              185,316                    
               TOTAL GAIN OR LOSS                            -65,316                  
               ACTIVITY SUMMARY                                                       
               TOTAL SECTION 1231 GAIN OR LOSS             -65,316                    

               On Schedule E, Supplemental Income and Loss, of petitioners'           
          1990 income tax return, petitioners reported a partnership loss             
          of $71,933 from Bass Associates consisting of a 1990 loss from              
          rental real estate activity of $20,573 and the suspended                    
          partnership losses from 1987 through 1989.  Statement 5 attached            
          to petitioners' 1990 return indicates that petitioner was a                 
          general partner of Bass Associates, which was engaged in rental             
          real estate activity.                                                       

                                       OPINION                                        

               The only issue for decision is whether the $65,316 loss that           
          petitioner sustained on December 30, 1990, is an ordinary or                
          capital loss.  Losses from sales or exchanges of capital assets             





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