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under section 1034 a gain of $341,710 realized on the sale of 20
The Point based on the rollover to 15 Sandpiper. Later, the
correct amount of deferred gain on the sale of 20 The Point was
determined to be $503,250.
Petitioners' 1989 Federal income tax return was prepared by
Robert McKenzie, who had been their accountant for more than 30
years. He maintains his office in San Bernardino, California.
McKenzie had also been the Corporation's accountant since its
incorporation in 1972.
Before the Corporation's liquidation, petitioners met with
McKenzie in June 1988 to discuss it. Petitioners also met with
McKenzie to discuss their 1989 tax return.
Activities
Between 1980 and 1989, petitioners were members of either
Palm Baptist Church or Magnolia Avenue Baptist Church, located in
Riverside. Petitioners also attended various churches from San
Diego to Palm Springs, such as Skyline Wesleyan Church in San
Diego.
Petitioners were members of Coronado Cays Yacht Club,
located in Coronado, California, and Shrimers Pictoria Country
Club, located in Riverside, California.
Petitioners continued to maintain bank accounts at Inland
National Bank in Riverside during 1988, 1989, and 1990. Also,
petitioners continued to receive mail at Mary Street after the
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