Roderick E. Carlson and Jeanette S. Carlson - Page 4




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          loan.  (For convenience, we shall refer collectively to the                 
          bank’s foreclosure on the Yantari and the concomitant sale of the           
          Yantari and other events that occurred on February 8, 1993, as              
          the foreclosure sale.)  As a result of the foreclosure sale,                
          petitioners realized capital gain of $28,621 and DOI income of              
          $42,142.                                                                    
               Immediately preceding the foreclosure sale on February 8,              
          1993, petitioners had (1) assets located in the States of Alaska            
          and Washington which had an aggregate fair market value of                  
          $875,251 and (2) liabilities which totaled $515,930.2  Included             

               2Petitioners’ description of petitioners’ liabilities imme-            
          diately preceding the foreclosure sale on Feb. 8, 1993, and the             
          amounts thereof stipulated by the parties are:                              
                  Description of                 Amount of                            
                  Liability                      Liability                            
                   Seattle First     $137,142 (principal)                             
                                     23,973 (interest)                                
                 Washington Mutual   96,280                                           
                HFC (2nd Mortgage)               61,546                               
                   Seattle First     9,575                                            
                   Seattle First     4,196                                            
                   Seattle First     11,456                                           
                 Seattle First Cr.   4,068                                            
                  Alaska Airlines    284                                              
                  Coastal Trans.     5,610                                            
                     Discover        1,710                                            
                   Hartig Rhodes     4,447                                            
                     HFC Visa        804                                              
                      Medden         1,246                                            
                     Nordstrom       806                                              
                    Bon Marche       1,855                                            
                  Guiness Assoc.     35,100                                           
                 Security Pacific    4,319                                            
                    HFC Charge       6,941                                            
                 Household Finance   2,828                                            
                                                             (continued...)           





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