Haralampos Katerelos and Irene Katerelos - Page 3

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            during 1986 with bases in excess of $22,102 to which the parties                              
            stipulated?  We hold that they did not.                                                       
                  (5) Are petitioners entitled to a general business credit                               
            carryforward from 1986?  We hold that they are not.                                           
                                          FINDINGS OF FACT2                                               
                  Some of the facts have been stipulated and are so found.                                
                  Petitioners resided in Tucson, Arizona, at the time the                                 
            petition was filed.                                                                           
                  Petitioners, who emigrated to the United States from Greece,                            
            have three children, all of whom they claimed as dependents in                                
            the returns that they filed for the years at issue.                                           
            Petitioners' Restaurant Business--New Dolce Vita                                              
                  In General                                                                              
                  Petitioners have been involved in the restaurant business in                            
            the United States since 1977.  In December 1985, petitioners                                  
            executed a lease for property located at 6781 North Thornydale in                             
            Tucson, Arizona, at which they planned to operate a restaurant                                
            called New Dolce Vita (NDV) that was to specialize in Italian,                                
            American, and Greek cuisine.  Petitioners provided all the                                    
            fixtures and equipment for the restaurant, some of which they                                 

            2  Petitioners' opening brief did not contain all of the findings                             
            of fact that petitioners wanted to propose and that they were                                 
            required to set forth in that brief, as required by Rule                                      
            151(e)(3).  Instead, in violation of that Rule, their answering                               
            brief contained additional proposed findings of fact that the                                 
            Court did not find to be "alternative proposed findings of facts"                             
            as permitted by Rule 151(e)(3).                                                               

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