G. Dastgir and Mary A. Qureshi - Page 3

               Petitioners G. Dastgir and Mary A. Qureshi, husband and wife,          
          resided in Richmond, Virginia, at the time they filed their                 
          petition. Petitioners timely filed a joint Federal income tax               
          return for 1984.                                                            
               G. Dastgir Qureshi (petitioner) is a physician. He received            
          his education and training in internal medicine and hematology              
          oncology at the Medical College  of  Virginia  and  Columbia                
          University.  In 1974, he joined the faculty of the Medical College          
          of Virginia. At all relevant times, petitioner was an assistant             
          professor at the Medical College of Virginia.                               
               In 1982, petitioners’ income was approximately $35,000.                
          During the year under consideration, 1984, petitioner received              
          wages of $77,916.                                                           
               FoodSource, Inc. (FoodSource)4 is a California company that,           
          during the period 1980-82, sold interests in controlled atmosphere          
          refrigerated containers to various investors.  The Budd Company of          

          see Noonan v. Commissioner, T.C. Memo. 1986-449, affd. without              
          published opinion sub nom. Hillendahl v. Commissioner, 976 F.2d             
          737 (9th Cir. 1992), and Brand v. Commissioner, T.C. Memo. 1988-            
               4    Beginning in May 1982, containers were sold by                    
          FoodSource Sales, Inc., a corporation wholly owned by David A.              
          Dixon, who owned or controlled a majority of FoodSource’s stock.            
          For simplicity, both FoodSource and FoodSource Sales, Inc. are              
          referred to herein as FoodSource.                                           

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