Barry B. Bealor and Nancy L. Bealor, et al. - Page 67

                                       - 151 -                                        
          should it be charged with the corresponding interest income or              
          other income reported, but not actually received as a result of             
          the sham transactions with the partnerships.  This again is a               
          matter for administrative adjustment by the parties.                        
               C.  No Need To Address Other Issues                                    
               As noted above, the Court of Appeals for the Third Circuit             
          has recently stated that "economic substance is a prerequisite to           
          any Code provisions allowing deductions."  United States v.                 
          Wexler, 31 F.3d at 124 (citing Lerman v. Commissioner, supra).              
          Here, the parties have raised other issues, some of them highly             
          technical.  In view of the pervasive lack of economic substance             
          in the transactions before us, we need not and do not address               
          them.                                                                       
               To reflect the foregoing,                                              

          An appropriate order will                                                   
          be issued.                                                                  


















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