National Industrial Investors, Inc. - Page 2

                           MEMORANDUM FINDINGS OF FACT AND OPINION                                     

                  NIMS, Judge:  Respondent determined the following                                    
            deficiencies and penalties in respect of petitioner's Federal                              
            income taxes:                                                                              
                  Taxable Year      Deficiency              Sec. 6662(a) Penalty                       
                  1989                    $12,284                 $2,457                               
                  1990                    12,251                  2,450                                
                  Unless otherwise indicated, all section references are to                            
            sections of the Internal Revenue Code in effect for the years at                           
            issue, and all Rule references are to the Tax Court Rules of                               
            Practice and Procedure.                                                                    
                  By amended pleadings, respondent asserted an increased 1990                          
            income tax deficiency in the amount of $88,162, and an increased                           
            1990 penalty under section 6662(a) in the amount of $17,632.  The                          
            parties settled the increased 1990 income tax deficiency, but the                          
            additionally asserted penalty remains disputed.  Petitioner has                            
            also claimed increased deductions for automobile mileage for both                          
            years and for dues and subscription expenses for 1990.                                     
                  After concessions, the issues for decision are:                                      
                  (1)  How much is petitioner entitled to deduct for business                          
            expenses for 1989 and 1990?  After concessions and additional                              
            claims by petitioner the following amounts are in contention:                              

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