Ferydoun Ahadpour, A.K.A. F. Ahadpour, and Doris Ahadpour - Page 2

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                                   Addition to Tax        Penalty                    
             Year     Deficiency    Sec. 6651(a)(1)      Sec. 6662(a)                 
             1989     $1,363,638       $340,560           $272,728                    
             1990        303,274           --               60,655                    
             1991        237,234         60,864             47,447                    
               The issues in this case, Iranian bad debt and domestic                 
          issues, have been bifurcated for separate resolution.  This                 
          opinion addresses the domestic issues.                                      
               After concessions by the parties,2 the sole issue for                  
          decision is whether certain payments received by petitioners                
          pursuant to a sale agreement for the sale of real property should           
          be included in gross income in the year received.                           
               This issue was submitted by the parties fully stipulated.              
          This reference incorporates herein the stipulation of facts and             
          attached exhibits.  At the time they filed their petition,                  
          petitioners resided in Huntington Beach, California.                        
                                  FINDINGS OF FACT                                    
          Sale Agreement                                                              
               On November 1, 1989, Doris and Ferydoun Ahadpour as sellers            
          entered into an “Agreement for Purchase and Sale of Real Property           
          and Escrow Instructions” (Agreement)  with buyer Coultrup                   

          2  The parties filed a Stipulation of Settled Issues with                   
          this Court on Apr. 17, 1998, resolving all domestic issues except           
          for the issue before this Court.  Furthermore, the parties agree            
          that additions to tax under sec. 6651(a)(1) and accuracy-related            
          penalties under sec. 6662(a) shall not apply to the domestic                
          issues for all years at issue.                                              

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