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America/Bradley to Mr. Marvin Goldstein, who assumed Mr. Bach's
capital account.4
As of January 1, 1987, Mr. Bach was a general partner of
Jama Mobile Home Parks Limited Partnership (JAMA). The principal
business of JAMA was the rental of trailers in Jacksonville,
Florida. As of January 1, 1987, Mr. Bach owned a 21.875-percent
loss-sharing interest in JAMA and had a deficit capital account
balance of $358,312.5 Also, as of the beginning of 1987, JAMA
had outstanding a total of $931,924 in mortgages, notes, and
bonds payable in 1 year or more.
During 1987, Mr. Bach made no capital contributions to JAMA.
During 1987, all the property of JAMA was sold or foreclosed
upon, and the partnership filed a final U.S. Partnership Return
of Income (Form 1065). On Form 1065, JAMA reported a gain of
$644,600 on the sale of its assets. On Schedule K-1, Partner's
Share of Income, Credits, Deductions, Etc., attached to
petitioners' 1987 return, Mr. Bach's allocable share of net gain
under section 1231 was $147,717. At the time he disposed of his
4Although the exact date that Mr. Bach assigned his interest
in America/Bradley to Mr. Goldstein is not clear from the record,
Mr. Bach received an allocable share of income, loss, deduction,
or credit from the partnership during 1987. The assignment was
treated as taking place at some point during 1987 when Mr. Bach's
deficit in his capital account was $448,756.
5Mr. Bach had a 22.916-percent profit-sharing interest and
ownership of capital interest.
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