Steven K. Stoddard and Ellen M. Stoddard - Page 6

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               In bankruptcy Schedule D, petitioners listed Credit Union              
          among their secured creditors.                                              
               On December 16, 1996, Credit Union filed a claim against               
          petitioners’ bankruptcy estate with respect to a loan of                    
          $84,192.13 that was secured by the Quissett.                                
               On January 8, 1997, the trustee of petitioners’ bankruptcy             
          estate (trustee) filed a document entitled “TRUSTEE’S REPORT OF             
          NO DISTRIBUTION” (trustee’s report) with the bankruptcy court.              
          In that report, the trustee stated, inter alia, that, except for            
          exempt property, no property had been received and no money had             
          been paid on account of petitioners’ estate and that there was no           
          property available for distribution from the estate.                        
               On February 21, 1997, the bankruptcy court granted petition-           
          ers a discharge.                                                            
               In May 1997, Credit Union foreclosed on a loan to petition-            
          ers that was secured by the Quissett and sold that boat for                 
               Credit Union issued Form 1099-C, Cancellation of Debt (Form            
          1099-C), to Mr. Stoddard for 1997.  Form 1099-C indicated that              
          the amount of debt canceled was $64,116.40.                                 
          Long-Term Capital Gain From the Sale of Certain Property                    
               During August 1990, petitioners purchased a condominium unit           
          (condo) for $165,000.  During 1993, 1994, and part of 1995,                 
          petitioners rented that condo.  On July 20, 1995, they sold it              

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