William Spencer Bach and Barbara Ruth Bach - Page 7

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          $190,501.  Wazee Street did not file a partnership return for               
          1987.                                                                       
               As of December 31, 1986, Mr. Bach owned a 37.5-percent                 
          interest as a general partner of 4139 Glenwood Joint Venture                
          (Glenwood).  Also, as of December 31, 1986, Mr. Bach had a                  
          deficit capital account balance of $4,198 and an allocable share            
          of nonrecourse liabilities of $47,423.                                      
               On February 3, 1987, Mr. Bach assigned his interest in                 
          Glenwood to Mr. Richard Segal for consideration of $10 and Mr.              
          Segal and Trans International Management, Inc., assigned their              
          interests in JAMA to Mr. Bach.  Mr. Bach's deficit capital                  
          account balance of $4,198 did not change between December 31,               
          1986, and the date of assignment.  Petitioners did not report any           
          gain in relation to the disposal of Mr. Bach's interest in                  
          Glenwood on their 1987 Federal income tax return.                           
               As of January 1, 1987, Mr. Bach was a general and limited              
          partner of Russell Street Limited Partnership (Russell Street).             
          Russell Street's primary business was investing in real estate.             
          Mr. Bach's percentage interests in Russell Street as a general              
          and limited partner were 24 percent and 1 percent, respectively.            
          As of the beginning of the year, Mr. Bach's capital account for             
          his interest as a general partner had a deficit balance of                  
          $51,349.                                                                    
               Sometime in 1987, Russell Street sold all its assets and               
          filed its final tax return.  As of the end of 1987, Mr. Bach no             




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