Paul G. Gubbini - Page 2

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          made by petitioner to Color Trick, Inc. (Color Trick); and (2)              
          whether petitioner may claim an ordinary loss pursuant to section           
          1244 attributable to the worthlessness of his stock in Color                
          Trick.  Unless otherwise noted, all section references are to the           
          Internal Revenue Code as in effect for the year in issue, and all           
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
                                  FINDINGS OF FACT                                    
               Some of the facts and certain exhibits have been stipulated            
          for trial pursuant to Rule 91.  The stipulated facts are                    
          incorporated herein by reference and are found accordingly.                 
               At the time he filed the petition in the instant case,                 
          petitioner resided in Dunedin, Florida.                                     
               Beginning in 1978 and during the times relevant to the                 
          instant case, petitioner was an anesthesiologist.  During 1980,             
          petitioner and certain other anesthesiologists formed a                     
          partnership known as Anesthesia Associates of Dunedin (medical              
          group) that provided services at a local hospital.  Petitioner              
          handled operation of the medical group.  Petitioner worked                  
          between 40 and 50 hours per week as an anesthesiologist and took            
          18 weeks of vacation per year.                                              
               From 1980 until 1984 or 1985, petitioner invested with a               
          builder in the construction and sale of homes on speculation.               
          Additionally, petitioner and another physician in the medical               
          group owned an apartment building.  Petitioner maintained the               




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