William Spencer Bach and Barbara Ruth Bach - Page 5

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          interest in JAMA during 1987, Mr. Bach had a deficit capital                
          account balance for his partnership interest in JAMA of $213,535.           
               As of December 31, 1986, Mr. Bach was a general partner of             
          the Bay Country Limited Partnership (Bay Country).  The principal           
          business of Bay Country was real estate rental and construction.            
          As of December 31, 1986, Mr. Bach owned a 23.75-percent profit,             
          loss, and capital-sharing interest in Bay Country and had a                 
          deficit capital account balance of $184,802.  As of the end of              
          1986, Mr. Bach's share of nonrecourse liabilities was $588,719.             
               On June 24, 1987, the partners sold their interests in Bay             
          Country to Rockville Central Building Corp. Number One and                  
          Rockville Central Building Corp. Number Two for $50,000.  Mr.               
          Bach received $5,000 on the sale of his interest in Bay Country.            
          At the time he sold his interest in Bay Country, Mr. Bach had a             
          deficit capital account balance of $184,802.  Petitioners did not           
          report on their 1987 Federal income tax return any gain regarding           
          the sale of Mr. Bach's partnership interest in Bay Country.                 
               As of January 1, 1987, Mr. Bach was a general partner of the           
          Diamond Farms Limited Partnership (Diamond Farms) and had a                 
          21.25-percent profit, loss, and ownership of capital interest in            
          the partnership.  The principal business of Diamond Farms was the           
          rental of real estate.  As of the beginning of 1987, Mr. Bach had           
          a deficit balance in his Diamond Farms capital account of                   
          $65,072.                                                                    






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