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(1) Whether any of the amount received from PepsiCo, Inc.
(PepsiCo), on the sale of petitioner's1 stock in Pizza Manage-
ment, Inc., is excludable from petitioners' income under section
104(a)(2). We hold that $295,461 is excludable.
(2) Whether legal fees and other expenses should have been
included in the basis of petitioner's stock in Pizza Management,
Inc., sold in 1990. We hold that $219,000 of the fees should
have been so included.
(3) Whether petitioner substantiated amounts included in
the basis of his failed investment in a T.J. Cinnamons Bakery
franchise. We hold that the amounts have not been substantiated.
(4) Whether petitioners are entitled to deduct the invest-
ment interest expense claimed on their 1990 Federal income tax
return related to loans from the United Bank of Fort Collins (the
bank). We hold that they are, in the amounts set out herein.
(5) Whether 1991 deductions claimed for attorney's fees
have been substantiated by petitioners. We hold that the fees
have not been substantiated.
(6) Whether petitioners are subject to the accuracy-related
penalty under section 6662(a) in connection with the filing of
their 1990 and 1991 Federal income tax returns. We hold that
they are not.
1All references to petitioner are to Wallace R. Noel.
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