Robert R. Plante and Mary B. Plante - Page 8

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                         Shareholder has transferred Four Hundred Seventy-            
                    Five Thousand ($475,000.00) Dollars of notes and                  
                    accrued interest of the Corporation due Shareholder as            
                    of 11/1/91 to the equity account of the Corporation and           
                    has made this an irrevocable capital contribution to              
                    the Corporation.  The notes, accrued interest and                 
                    capital lease due Shareholder as of the Closing have              
                    been tendered to Buyer in exchange for Buyer notes.               

          Petitioner wrote "PAID IN FULL" and the date of "12-20-91" on               
          each note.                                                                  
               Petitioners' 1991 Federal income tax return (the 1991                  
          return) was prepared by Russell Marshall, a certified public                
          accountant.  Mr. Marshall advised petitioner that the transaction           
          in which petitioner transferred his interest in BCBI to the                 
          Hansens resulted in a long-term capital loss, only a portion of             
          which was currently deductible.  On the Schedule D attached to              
          their 1991 return, petitioners reported a basis of $1,743,492 in            
          the BCBI stock and reported a long-term capital loss of $693,492            
          from its sale.2  Petitioners deducted $3,000 of this loss and               
          treated the remaining portion as a long-term capital loss                   
          carryover to 1992.                                                          
               On March 26, 1993, petitioners filed an amended 1991 return.           
          On the amended return, petitioners treated the BCBI stock as                
          small business stock defined by section 1244 and claimed an                 

               2In preparing petitioners' original and amended 1991 Federal           
          income tax returns, the allocation schedule in the agreement was            
          obviously ignored, and petitioners reported the transaction as              
          though the entire purchase price was attributable to the sale of            
          BCBI stock.  See infra note 3.                                              

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