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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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