G. Dastgir and Mary A. Qureshi - Page 2

          section 6659 addition to tax, respondent determined a $1,879                
          addition to tax for substantial understatement of tax pursuant to           
          section 6661.                                                               
               Following concessions by petitioners,2 the issues for decision         
          are: (1) Whether a closing agreement entered into by the parties on         
          August 7, 1989, precludes petitioners from entitlement to a claimed         
          depreciation deduction, investment tax credit, and loss from a              
          program marketed by or on behalf of FoodSource, Inc. (hereinafter,          
          this program is referred to as the FoodSource program) for 1984;            
          and if not, (2) whether petitioners are entitled  to  the                   
          depreciation deduction, investment tax credit, and loss for 1984.           
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  The          
          stipulation of facts and the attached exhibits are incorporated             
          herein by this reference.  The record before us is incomplete;              
          nonetheless, we have attempted, as best we can, to ascertain the            
          facts necessary to resolve the issues before us.3                           

          sec. 1511(c)(1), 100 Stat. 2744, former sec. 6621(d) was                    
          redesignated as sec. 6621(c).                                               
                    Except as otherwise indicated, all section references             
          are to the Internal Revenue Code for the year under                         
               2    Petitioners acknowledge that in the event we sustain              
          respondent’s deficiency determination, they are liable for both             
          the sec. 6659 addition to tax and additional interest pursuant to           
          sec. 6621(c).                                                               
               3    For a better understanding of the FoodSource program,             

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