Estate of James F. Hall, Jr., Deceased, Harriet Hall, Executrix, and Harriet Nixon Hall - Page 2

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          Inc., Pension Plan under section 105(c)1 and, if not, whether               
          petitioner Harriett Nixon Hall is entitled to relief from                   
          liability as an "innocent spouse" under section 6013(e).                    

                                  FINDINGS OF FACT                                    

               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and attached exhibits are incorporated             
          herein by this reference.  At the time of the filing of the                 
          petition in this case, petitioners resided in Carnegie,                     
          Pennsylvania.2  Petitioner James F. Hall, Jr., died on January              
          12, 1994, after the petition was filed but before trial.  His               
          estate filed a Motion for Substitution of Party and to Change               
          Caption, which was granted by the Court.                                    
               Together petitioners owned 100 percent of the stock of Hadd-           
          Too, Inc. (Hadd-Too).  Hadd-Too adopted a defined benefit pension           
          plan (Plan or Hadd-Too Plan) and trust, effective January 1,                
          1981, which was subsequently amended and restated, effective                
          January 1, 1984.  The Plan was a qualified plan within the                  
          meaning of section 401(a).  On November 19, 1986, Hadd-Too                  
          resolved to terminate its Plan, effective December 31, 1986,                


          1Unless otherwise indicated, all section references are to                  
          the Internal Revenue Code in effect for the taxable year in                 
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
          2At the time they filed their petition herein, petitioners                  
          were involved in divorce proceedings and did not reside together.           




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