Joseph D. Doll and Charlotte J. Doll - Page 2

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          6651(a)(1)1 addition to tax of $10,812.  After a concession,2 the           
          issues for decision are:  (1) Whether petitioners had any basis             
          in the partnership interests which they sold during 2001 for                
          $199,375, and (2) whether petitioners can exclude any part of the           
          $199,375 proceeds from the sale of the partnership interests from           
          taxable income in 2001.                                                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time they filed              
          the petition, petitioners resided in Broomfield, Colorado.  All             
          references to petitioner in the singular are to Joseph D. Doll.             
               Petitioner organized Custom Design and Manufacturing (CDM)             
          and Accelerated I/O (AIO), both Delaware C corporations.                    
          Petitioner also formed Colorcom Ltd. (Colorcom), a Colorado                 
          limited partnership.  CDM is the general partner of Colorcom.               
          Petitioner is the president of CDM and owns 80 percent of the               
          stock of CDM.  Colorcom owns 80 percent of AIO, and AIO owns 80             
          percent of Colorcom.  CDM, Colorcom, and AIO are all working on             



               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  
               2  Respondent conceded that no addition to tax pursuant to             
          sec. 6651(a)(1) is due from petitioners for 2001.                           




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