Michael Hillyer and Teresa Hillyer, et al. - Page 2

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          submitted to the Court on a full stipulation of facts and                   
          exhibits without trial, pursuant to Rule 122.  All statutory                
          references are to the Internal Revenue Code in effect for the               
          year in issue, and all Rule references are to the Tax Court Rules           
          of Practice and Procedure, except as otherwise noted.                       
               On September 2, 1994, respondent determined deficiencies in            
          petitioners' 1991 Federal income taxes in the following amounts:            
          Petitioners                   Docket No.    Deficiency                      
          Michael & Teresa Hillyer              22118-94     $13,798                  
          David D. & Linda J. Hillyer           22119-94      13,576                  
          William H., Jr., & Kim Rae Hillyer    22120-94      12,724                  
          William H., Sr., & Elizabeth Hillyer  22121-94      44,077                  
               All the above petitioners, husbands and wives, filed joint             
          income tax returns for the year 1991 at Kansas City, Missouri,              
          and, at the time of filing the petitions herein, all such                   
          petitioners were residents of Illinois.  All the male petitioners           
          (petitioners) herein were stockholders of Hillyer Excavating                
          Service, Inc. (the corporation), whose name was changed to                  
          Hillyer, Inc., in 1992.                                                     
               During the 1991 calendar year, the shares of the corporation           
          were owned as follows:                                                      
          Percent                                                                     
          Michael Hillyer           15.44                                             
          David D. Hillyer          15.47                                             
          William Hillyer, Jr.      15.47                                             
          William Hillyer, Sr.      53.59                                             
          Total             100                                                       
               For the year 1991, the corporation filed Form 1120-S as an S           
          corporation, and attributed its net income to petitioners in                




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