Clinton N. and Naomi K. Bohannon - Page 10

                                                  10                                                    
                  Petitioners reported income from the sale of Bohannon, S.A.                           
            stock from 1973 to 1989 as follows:                                                         
                        Year        Income from Sale of Bohannon, S.A. Stock                            
                                    Reported on Petitioners’ Return                                     
                        1973                           -0-                                              
                        1974                           -0-                                              
                        1975                           -0-                                              
                        1976                           -0-                                              
                        1977                    Not in record                                           
                        1978                           -0-                                              
                        1979                           -0-                                              
                        1980                           -0-                                              
                        1981                    Not in record                                           
                        1982                    $875,000                                                
                        1983                           -0-                                              
                        1984                           397,673                                          
                        1985                           793,816                                          
                        1986                           642,972                                          
                        1987                           -0-                                              
                        1988                           218,000                                          
                        1989                        219,500                                             
                        Total                   3,146,961                                               
                  A general business credit was reported on petitioners' Forms                          
            K-1 from 1976 to 1985.  Petitioners attached Forms 3800, General                            
            Business Credit, to their 1988 and 1989 returns.  On them,                                  
            petitioners reported but did not claim a $27,548 carryforward of                            
            the general business credit for 1988 and 1989.                                              
                  Petitioners reported gains from the sale of stock of                                  
            Bohannon, S.A. ($875,000) and Hardwoods, S.A. ($287,100) on their                           
            1982 return.  Hardwoods, S.A. was another Panamanian corporation                            
            in which petitioner owned stock.  Petitioners made no section                               
            172(d) computations on their 1982 return.                                                   








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