Robert Lee McWilliams - Page 4

                                                - 4 -                                                 
            Education                                                         1,461                   
            Repairs                                                           15,529                  
            Supplies                                                   235                           
                                                                        23568,899                     
            Total                         77,084            79,632                                    
            Petitioner has substantiated $47,144, $51,007, and $38,661 of the expenses for            
            the years 1986, 1987, and 1988, respectively.  In addition, respondent has                
            conceded that $7,767, $5,591, and $8,569 of the expenses are deductible on                
            Schedule A of the 1986, 1987, and 1988 returns, respectively, subject to                  
            limitations (i.e., personal interest.  Sec. 163(d)(6)(B)).                                
            Relationship Between Petitioner And Gilbert                                               
                  Petitioner and Dr. Alton L. Gilbert (Gilbert) met in 1968.  They had a              
            close personal relationship for many years, and a business relationship during            
            many of those years.  Gilbert and his wife were also members of petitioner's              
            ministry for 20 years.                                                                    




            Twenty-First Century Corporation (TFC)                                                    
                  TFC was formed in 1979.  Petitioner, Gilbert, and their wives owned the             
            stock in TFC.  Petitioner never contributed money or property to TFC, only                
            services.  TFC elected Subchapter S status from its inception.  TFC's original            
            business (to grow and sell pine trees) failed.  Gilbert had some experience               
            with computers so TFC entered the computer services business.  TFC's computer             
            business was sold to Technical Services, Inc., effective April 1, 1984.                   
            Technical Services, Inc. (TSI)                                                            
                  TSI was incorporated on August 18, 1983.  It elected subchapter S status            
            effective January 1, 1984.  TSI was also in the business of providing computer            
            services.  The principal shareholders of TSI were Gilbert and Mr. John Robbins            
            (Robbins).                                                                                
            Sale Of Assets From TFC To TSI                                                            
                  In 1983 and 1984, TFC furnished computer services for TSI's clients.                
            TFC and TSI attempted to form a joint venture called Systech Management to                





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