Mark A. and Juanita D. Murdock - Page 3

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                   Additions to Tax                                                                    
            Sec.         Sec.       Sec.                                                               
            Year     Deficiency      6653(b)       6661       6663                                     
            1988       $9,394        $7,046       $2,349       --                                      
            1989        6,565          -0-          --       $4,924                                    

                  A timely petition was filed on behalf of petitioners by an                           
            attorney who is admitted to practice before this Court.  At the                            
            time the petition was filed, and at the time the subject motion                            
            was filed, petitioners were legal residents of the State of                                
            Michigan.  Subsequent to filing the petition, respondent filed an                          
            answer and affirmatively alleged that petitioners were liable for                          
            fraud pursuant to sections 6653(b) and 6663, respectively, for                             
            the years 1988 and 1989.  Counsel for petitioners thereafter                               
            filed a reply to the affirmative allegations pursuant to Rule 37.                          
            In due course, a notice was issued by this Court calendaring this                          
            case for trial at the Court's Detroit, Michigan, trial session                             
            commencing on January 31, 1994.                                                            
                  On January 5, 1994, counsel for petitioners, John C.                                 
            Griffin, Jr. (Mr. Griffin), and Mark A. Murdock (petitioner) met                           
            with counsel for respondent, Dennis G. Driscoll (Mr. Driscoll),                            
            at respondent's offices.  Petitioner Juanita D. Murdock was not                            
            present at this meeting.  At the meeting, the parties reached a                            
            basis for settlement of the case.  A stipulated decision document                          
            was prepared and signed on that date by Mr. Griffin and Mr.                                
            Driscoll, counsel for the parties.  In that decision, the parties                          




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