Richard J. Salem and Eileen L. Salem - Page 3

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          A.   Petitioners                                                            
               Petitioners Richard J. Salem (Mr. Salem) and Eileen L. Salem           
          (Mrs. Salem) are married and resided in Tampa, Florida, when they           
          filed their petition in this case.  Mr. and Mrs. Salem are                  
          hereinafter sometimes referred to as the Salems.                            
               Petitioners Robert S. Saxon (Mr. Saxon) and Bernice S. Saxon           
          (Mrs. Saxon) are married and resided in Clearwater, Florida, when           
          they filed their petition in this case.  Mr. and Mrs. Saxon are             
          hereinafter sometimes referred to as the Saxons.                            
          B.   Salem, Saxon & Nielsen, P.A.                                           
               1.   Background                                                        
               Mr. Salem and Mrs. Saxon are attorneys who are shareholders            
          in the law firm of Salem, Saxon & Nielsen, P.A. (SS&N).  During             
          the taxable year 1990, Mr. Salem owned 450 shares of the stock of           
          SS&N, and Mrs. Saxon owned 50 shares.  Their general law practice           
          is business oriented and includes litigation.  Mr. Salem was                
          admitted to practice before this Court in 1975.                             
               During the mid-1980's, SS&N began borrowing money from the             
          Bank of Tampa (the bank).  From 1987 through 1990, the bank made            
          loans to SS&N on the following dates in the amounts indicated:              











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