Leo and Alla Goldberg - Page 9

                                         -9-                                          
               In August 1988, petitioners entered into an exchange                   
          agreement under which they would exchange their interest in the             
          Detroit properties for yet unspecified property that was subject            
          to a mortgage of at least $106,523.  By grant deed dated August             
          31, 1988, petitioners transferred their interest in the Detroit             
          properties to IEC.  IEC and the Landaus then conveyed the Detroit           
          properties to a purchaser for $365,000, or $182,500 for                     
          petitioners' one-half interest.  On their 1988 return,                      
          petitioners reported that their adjusted basis in the Detroit               
          properties was $132,840 and that the Detroit properties were sold           
          in a transaction in which no gain or loss was recognized under              
          section 1031.  By the end of 1988, petitioners had taken                    
          depreciation on the Detroit properties equal to $14,073.                    
               On or about July 10, 1986, petitioners acquired an interest            
          in certain real property in Huntington Beach, California, known             
          as the 8th Street property.  On or about August 19, 1986,                   
          petitioners acquired an additional interest in the 8th Street               
          property.                                                                   
               In September 1988, petitioners entered into an exchange                
          agreement with IEC to exchange their interest in the 8th Street             
          property for, as of then, unidentified property.  By grant deed             
          dated September 12, 1988, petitioners transferred their interest            
          in the 8th Street property to IEC.  IEC then conveyed the 8th               
          Street property to a purchaser for $344,000.  Petitioners                   
          reported that their adjusted basis in the 8th Street property was           




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