Terry Duane Beall and Joyce Engel Beall - Page 9

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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.                                  
               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               
               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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