Michael A. Conviser and Barbara L. Conviser - Page 2

          not.  See Nelson v. Commissioner, 110 T.C. 114, 130 (1998), on              
          appeal (10th Cir., May 8, 1998).                                            
               Section references are to the Internal Revenue Code.  Rule             
          references are to the Tax Court Rules of Practice and Procedure.            
               The parties submitted this case fully stipulated under Rule            
          A.   Petitioners                                                            
               Petitioners lived in Aspen, Colorado, when they filed the              
          petition in this case.                                                      
          B.   Mikama, Inc.                                                           
               Petitioners were shareholders in Mikama, Inc. (Mikama), from           
          1988 to 1995.  Mikama was an S corporation during the years in              
          issue.  Petitioners owned a one-third interest in Mikama during             
          the years at issue.                                                         
               1.   Dove Canyon                                                       
               From 1987 to 1995, Mikama was a general partner with a 10-             
          percent interest in a limited partnership known as Dove Canyon              
          Co. (Dove Canyon).  Dove Canyon was formed in 1987 to develop 874           
          acres of real property in Orange County, California.  After it              
          bought the land, Dove Canyon built the major improvements on the            
          property, including roads, a sewage system, a golf course, a                
          clubhouse, and a swim and tennis club, and sold parcels of the              
          development to builders to build homes on lots for sale to                  
          individuals.  Dove Canyon sold the last parcel in 1993.                     

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