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“Oakmark ILA Gov’t”, and “FSP--Pacific Basin”. Petitioner and
intervenor received the rental income that they reported on the
1994 return from two residential properties: “Sunny Trail
Heights” and “Golden Gates”. Petitioner and intervenor reported
taxable income of $565,136 and total tax of $200,098 for 1994.
Petitioner and intervenor signed the 1994 return on October 14,
1996. The IRS received the 1994 return on October 17, 1996.
Martinez prepared the 1994 return.
On their joint income tax return for 1995 (1995 return),
petitioner and intervenor reported the following sources of
income:
Source Amount of Income
Net long-term capital gain $43,365
Universal Painters 254,640
A large portion of the net long-term capital gain was
attributable to the redemption of 15,510.497 shares of Founders
Growth Fund, one of the Founders Funds mutual funds jointly owned
by petitioner and intervenor, on December 14, 1995. This
redemption generated a $65,698 long-term capital gain.
Petitioner and intervenor reported taxable income of $293,619 and
total tax of $87,639 for 1995. Petitioner and intervenor signed
the 1995 return on October 14, 1996. The IRS received the 1995
return on October 17, 1996. Martinez prepared the 1995 return.
Petitioner and intervenor paid the income tax liabilities
reported on their joint income tax returns for 1990 through 1995
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