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pursuant to the terms of the 1979 closing agreement.
Petitioner and Mrs. Wang timely filed their 1989 Federal
income tax return, which was received by the Internal Revenue
Service on October 11, 1990. On their 1989, 1990, and 1991
Federal income tax returns, the Wangs elected to use the
4(...continued)
11281-83, is currently before the United States Tax
Court;
WHEREAS, the proceeds from sales of real estate in 1979
were not fully recognized in 1979 or later years;
WHEREAS, the parties hereto wish to determine with
finality the taxpayers' tax liability for the tax year
1979 and the timing of the recognition of the gains
from those 1979 real estate transactions;
NOW IT IS HEREBY DETERMINED AND AGREED for Federal
income tax purposes, that:
(1) there will be no recognition of the gain from the
disputed sales of real estate in 1979;
(2) there is no tax due from, nor refund due to, the
taxpayers for the tax year 1979;
(3) taxpayers are to recognize the gains from the
disputed 1979 sales of real estate, resulting in
increases to their income of $1,369,723 on the
corporate income tax returns of EIC Group, Inc. as
follows:
(a) $500,099.50 income is to be included in the
tax year 1989;
(b) $500,099.50 income is to be included in the
tax year 1990;
(c) $369,524.00 is to be reported in the year it
is paid by the buyer to, or for, the taxpayer;
(4) there are no other items of income nor expense to
be included as income, or taken as a deduction, with
respect to the 1979 real estate transactions except as
stated in (3) above.
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