Estate of Donald H. Ray, Deceased, Patricia G. Ray, Independent Executrix, and Patricia G. Ray - Page 3

               All section references are to the Internal Revenue Code as             
          in effect for the years in issue, and all Rule references are to            
          the Tax Court Rules of Practice and Procedure.                              
                                  FINDINGS OF FACT                                    
               These cases are consolidated for trial, briefing, and                  
          opinion.  Some of the facts have been stipulated and are found              
          accordingly.  We incorporate by reference the stipulation of                
          facts and attached exhibits.                                                
               Petitioners are the Estate of Donald H. Ray (Mr. Ray),                 
          Deceased, Patricia G. Ray, (Mrs. Ray) Independent Executrix, and            
          Patricia G. Ray, and Cipriano Dominguez and the Estate of Isabel            
          Dominguez (Mrs. Dominguez), Deceased, Cipriano Dominguez,                   
          Independent Executor.  At the time the petition was filed in                
          docket No. 4582-93, Mrs. Ray resided in Arlington, Texas.  At the           
          time the petition was filed in docket No. 4583-93, the                      
          Dominguezes resided in Arlington, Texas.                                    
               In 1981, Mr. Ray, Mrs. Dominguez, and Robert F. Breese                 
          (Breese) began investing together in various entities.  Breese is           
          a certified public accountant with a bachelor's degree in                   
          business administration in accounting; however, he does not                 
          actively practice in accounting.  They formed RDB Joint Venture             
          (RDB), a Texas general partnership, and Breese managed RDB's                
          investments.  Mr. Ray died in December 1990, and prior to that              
          time Mrs. Ray did not actively participate in the Rays'                     
          investments.  Mrs. Dominguez died in June 1993.                             

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