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share of his right, title and interest in the above
referenced Partnership.
* * * * * *
3. Each of the parties hereto agrees to execute any
and all documents necessary or appropriate to transfer
their interests hereby conveyed or to be conveyed to
the Partnership interest in the property owned by the
Partnership or the Lease Agreement as it pertains to
the property if necessary.
Petitioners filed their Federal income tax returns (returns)
for taxable year 1990 on or about May 20, 1992, and for taxable
year 1991 on or about June 3, 1994.
Petitioners claimed Schedule C business expenses in the
amounts of $188,104 for taxable year 1990 and $171,182 for
taxable year 1991. Respondent disallowed business expenses to
the extent of $118,371 for taxable year 1990 and $144,187 for
taxable year 1991.
Petitioners claimed Schedule E losses in the amount of
$17,751 for taxable year 1990 and $12,686 for taxable year 1991.
Respondent disallowed losses to the extent of $15,966 for taxable
year 1990 and $12,686 for taxable year 1991.
On their return for taxable year 1991, petitioners claimed
Schedule A itemized deductions in the amount of $56,927.
Respondent disallowed deductions to the extent of $9,244.
Respondent has conceded that, before statutory limitations,
petitioners are entitled to additional deductions for real estate
taxes in the amount of $7,732, charitable contributions in the
amount of $7,715, and interest expense in the amount of $15,968.
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