Raymond R. Weigel - Page 7

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          with a $45,000 reduction to that amount for the accrual of                  
          Goshorn's rent to petitioner.  For Goshorn's tax year ending                
          October 31, 1989, Goshorn reported unappropriated retained                  
          earnings of $867,324.                                                       
               During all of the tax years at issue, petitioner and Goshorn           
          each held 50 percent of the shares of stock in Racon Construction           
          Co. (Racon), a C corporation engaged in construction.  The com-             
          bining balance sheet of Goshorn and Racon for their tax years               
          ended October 31, 1990, reflects as an asset $392,617 as the                
          amount due from stockholder.  The detailed balance sheets of                
          Goshorn state that, as of September 30, 1991, there was                     
          $379,898.05 due from the stockholder.                                       
          Late Filing Penalty                                                         
               Petitioner requested an automatic extension for filing a               
          1987 Federal income tax return until August 15, 1988, and a                 
          further extension for filing until October 15, 1988.  Petitioner            
          and his wife filed their joint 1987 Federal income tax return on            
          August 16, 1990.                                                            
               Petitioner applied for and received an extension of time to            
          file a 1988 Federal income tax return until October 16, 1989.               
          Petitioner and his wife filed their joint 1988 Federal income tax           
          return on October 11, 1990.  Petitioner and his wife filed their            
          joint 1990 Federal income tax return on October 6, 1992.                    








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