- 12 - to pay off the total obligation and that they would be ready to go through with the transaction on December 4, 1978. Jack Ham agreed to pay both principal plus accrued interest, which on December 4, 1978, would total $38,334.50. Henry Hooker (Hooker), an attorney, who also was a limited partner in South Texas Drilling, was responsible for preparing two separate assignments of partnership interest, one from petitioner to Jack Ham, and the other from petitioner to Redi- Built for purchase prices of $23,334.50 and $15,000, respectively. The $38,334.50 total purchase price was paid with two checks, each made payable to Commerce Bank for the above stated amounts. Pursuant to the transfer, Jack Ham and Bert Ham received an interest of 60.87 percent and 39.13 percent, respectively of petitioner's 2.4 percent interest in South Texas Drilling. Upon receiving the two checks, Commerce Bank used the funds to retire petitioner's outstanding oil partnership debt. On December 27, 1978, Jack Ham assigned his interest in South Texas Drilling to Bert Ham for $334.50. Jack Ham had previously told Harris that he would resell the oil partnership interest to Bert Ham prior to the end of the year at a loss for tax purposes. Petitioners failed to report the receipt of the $38,334.50 in 1978 on their original Form 1040. On March 26, 1980, petitioners filed an amended 1978 Federal income tax return, FormPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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