Robert Serenbetz and Karen J. Serenbetz - Page 3

                Robert Serenbetz is a business executive.  During the years                  
          under consideration, he was the president and chief operating                      
          officer of DNA Plant Technology Corporation, an agricultural                       
          biotechnology company.  Prior thereto, he was a vice president of                  
          Warner-Lambert Co. and the president of American Chicle.  Mrs.                     
          Serenbetz is a homemaker.                                                          
                During the years under consideration, petitioners owned a                    
          condominium  in  Notch  Brook  Resort  Condominiums,  a  50-unit                   
          development located in Stowe, Vermont (the  Vermont condominium).                  
          All condominium owners were members of the condominium association,                
          and those condominium owners who wished to rent their units to                     
          third parties were partners in the Notch Brook Hotel Condominium                   
          Partnership (the partnership).  Petitioners were members of the                    
          partnership, as were about 40 other owners.                                        
                The condominium association was governed by a board of                       
          directors.  Mr. Serenbetz was a member of the board of directors of                
          the condominium association in both 1991 and 1992.  That board met                 
          on a regular basis, and Mr. Serenbetz sometimes participated in                    
          meetings by telephone.  In 1991, Mr. Serenbetz spent 36 hours                      
          preparing for and attending meetings, reviewing minutes of                         
          meetings, and discussing the meetings with his wife.  Mr. Serenbetz                
          spent 22 hours in 1992 preparing for and attending board meetings                  
          and reviewing minutes of the board meetings.                                       
                The day-to-day rental operation of the partnership was run and               
          managed by an on-site staff of nine employees of both the                          

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