Ann E. Bartak - Page 12

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          local taxes, and a $34,923 Schedule E loss.  Most of the Schedule           
          E loss ($32,288) was attributable to the Hoyt partnerships.5  The           
          total tax listed was zero.  The Federal income tax withheld                 
          listed was $6,532.                                                          
               In 1984, petitioner and Mr. Bartak sold their real estate              
          partnership investment.  Petitioner and Mr. Bartak had a large              
          capital gain ($112,247) associated with the sale of this                    
          investment.                                                                 
               On their joint income tax return for 1984, petitioner and              
          Mr. Bartak reported $51,993 in wages.  In arriving at total                 
          income, the only additions and subtractions were $9,785 in                  
          interest income, $1,707 in taxable refunds of State and local               
          taxes, a $112,247 capital gain (related to the sale of the real             
          estate partnership investment), and a $146,112 Schedule E loss.             
          Most of the Schedule E loss ($143,278) was attributable to                  
          petitioner and Mr. Bartak’s investment in the Hoyt partnerships.            
          The total tax listed was $92.  The Federal income tax withheld              
          listed was $5,874.                                                          
               On their joint income tax return for 1985, petitioner and              
          Mr. Bartak reported $48,667 in wages.  In arriving at total                 
          income, the only additions and subtractions were $10,249 in                 
          interest income, $454 in dividends, $1,343 in taxable refunds of            


               5  We make no finding that petitioner and Mr. Bartak’s                 
          initial Hoyt partnership investment actually was in 1983.                   





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