Derwyn J. Booker - Page 3

               (7) Whether petitioner is liable for increased interest                
          under section 6621(c).  We hold that he is.                                 
               (8) Whether petitioner is liable for a penalty for                     
          maintaining a frivolous action under section 6673.  We hold that            
          he is not.                                                                  
                                  FINDINGS OF FACT                                    
               The stipulation of facts and the attached exhibits are                 
          incorporated herein.  Petitioner resided in Toledo, Ohio, at the            
          time the petition was filed.                                                
               Petitioner has a bachelor of science degree in mechanical              
          engineering and was employed as an engineer for the Tosco Corp.             
          in its oil refinery at Bakersfield, California.  Petitioner                 
          received unemployment compensation in the amount of $5,312 in               
          1984.  In 1984, after leaving Tosco, petitioner started a                   
          business named J. Booker and Co., offering financial advice.                
          Encore Leasing                                                              
               During 1983, petitioner investigated a number of tax                   
          shelters before deciding to participate in the Encore Leasing Tax           
          Shelter Program as both an investor and a promoter.  Petitioner             
          was the managing partner of BBG, Ltd.(BBG), which was composed of           
          petitioner and two other individuals.  On December 27, 1984,                
          petitioner, acting on behalf of BBG, entered into a lease                   
          transaction with Encore Leasing Corp. (Encore); the lease                   
          indicates that BBG’s total investment in the program was $14,880.           

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