William Spencer Bach and Barbara Ruth Bach - Page 9

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               In addition to transactions not reported on Schedule D of              
          petitioners' 1987 return, petitioners failed to report:  Rental             
          income of $1,608 received from Solon Automated Services; an IRA             
          distribution of $1,830 received from Putnam Option Income Trust;            
          and interest income totaling $1,711 from various partnerships and           
          banks.  Finally, during 1987, Ms. Bach contributed $4,000 to her            
          IRA held by Putnam Option Income Trust.                                     
               Petitioners filed their 1987 Federal income tax return with            
          the Internal Revenue Service Center at Philadelphia,                        
          Pennsylvania, on November 21, 1988.                                         

                                       OPINION                                        

          Recognition of Gain or Loss on Disposition of Partnership                   
          Interests                                                                   

               Respondent determined a deficiency for 1987 due to capital             
          gains not reported by petitioners on the disposition of several             
          partnership interests as follows:                                           
                                                                                     
                    Partnership           Capital Gain                                
                    America/Bradley           $448,756                                
                    JAMA                       213,535                                
                    Bay Country                189,802                                
                    Diamond Farms               66,823                                
                    Wazee Street                39,432                                
                    Glenwood                     4,208                                
                    Russell Street              21,005                                
                    Total                   $983,561                                  







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