American Underwriters, Inc. - Page 32

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          have acted under the circumstances herein.  It is also relevant             
          that petitioner's 1987 and 1988 tax returns were prepared by the            
          C.P.A., who was knowledgeable about the business and operation of           
          all of the entities herein.                                                 
                                                                                     
               In reaching all of our holdings herein, we have considered             
          each argument made by respondent for contrary holdings, and, to             
          the extent not mentioned above, find them to be irrelevant or               
          without merit.                                                              
               To reflect the foregoing,                                              
                                                 Decision will be entered            
                                            under Rule 155.                          

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