James H. Leste and Stacy Leste, et al. - Page 3

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          Associates Ltd. Corp. for James H. Leste's and Richard W. Moore's           
          purchase of FAMC's stock, and thus nondeductible by FAMC and                
          taxable as constructive dividends to the individual petitioners, as         
          respondent contends;                                                        
               (2) whether all petitioners are liable for the accuracy-               
          related penalty under section 6662(a) pertaining to the above               
          issue;                                                                      
               (3) whether the Lestes and the Moores are liable for the               
          accuracy-related penalty under section 6662(a) for failing to               
          properly report bonus income received from FAMC on their individual         
          income tax returns; and                                                     
               (4) whether FAMC is liable for the accuracy-related penalty            
          under section 6662(a) for overstating its cost of goods sold by             
          $202,525 for its fiscal year ended October 31, 1991.                        
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are found                   
          accordingly.  The stipulation of facts and the attached exhibits            
          are incorporated herein by this reference. At the time of the               
          filing of the petitions, the Lestes and the Moores resided, and             
          FAMC's principal place of business was located, in California.              
               FAMC was incorporated on February 26, 1986; it was a wholly            
          owned subsidiary of Valentine Associates Limited Corp. (VALC).              
          VALC was incorporated in 1973 and was engaged in the business of            
          providing collection and accounting services to mortgage lenders            
          (loan servicing).  At all relevant times, Silbernagel owned all the         
          stock of VALC and was its president.  From 1969 until the time VALC         



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