Peter and Ursula Reimann, et al. - Page 17

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          His wife, Suzanne Yarnell, was not employed outside the home.  On           
          their 1981 Federal income tax return, Marvin and Suzanne Yarnell            
          reported gross income from wages of $350,000 and total income in            
          the amount of $374,178.  Consequently, in the absence of                    
          significant deductions or credits, they were subject to payment             
          of Federal income taxes in substantial amounts.                             
               Philip Yarnell was a salesman and 25-percent owner of                  
          Yarnell Fabrics and YFIL during 1981.  His spouse, Roberta, was             
          employed as a travel consultant during that year.  On their 1981            
          Federal income tax return, Philip and Roberta Yarnell reported              
          gross income from wages of $300,000 and total taxable income in             
          the amount of $296,787.  Consequently, in the absence of                    
          additional deductions or credits, they were subject to payment of           
          Federal income taxes in substantial amounts.                                
               For an investment of $75,000, Marvin Yarnell acquired a                
          7.62-percent interest in Plymouth in 1981.  As a result of the              
          passthrough from Plymouth, on their 1981 Federal income tax                 
          return, Marvin and Suzanne Yarnell deducted an operating loss in            
          the amount of $60,952 and claimed investment tax and business               
          energy credits totaling $124,034.  Respondent disallowed Marvin             
          and Suzanne Yarnell's claimed operating loss and credits related            
          to their investment in Plymouth.                                            
               Also during 1981, Philip Yarnell acquired a 6.35-percent               
          interest in Plymouth for an investment of $62,500.  As a result             
          of the passthrough from Plymouth, on their 1981 Federal income              
          tax return, Philip and Roberta Yarnell deducted an operating loss           



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