Gerald L. and Joy M. Zeidler - Page 4

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          Ladish during the years at issue until June 1992 as a                       
          stenographer.  She was classified by her employer as a Steno III,           
          having progressed from Steno I and Steno II.  Her work was                  
          entirely administrative, and, at some point, in addition to her             
          work as stenographer, she became manager of the company store               
          that stocked gifts and other paraphernalia bearing the Ladish               
          logo.  Mrs. Zeidler's employment with Ladish terminated in June             
          1992 after 18 years of service.  She was terminated because of              
          adverse business and economic conditions facing Ladish.  For                
          several years prior to 1992, Ladish had been faced with such                
          problems and had, over the years, laid off or terminated                    
          employees, beginning with employees having less seniority.                  
               On their Federal income tax returns for 1990, 1991, and                
          1992, petitioners claimed charitable contribution deductions of             
          $141, $211, and $143, respectively, for contributions to an                 
          organization in Greendale, Wisconsin, known as the Cantare                  
          Chorale singers (the organization).3  The organization at one               

               The charitable contribution adjustments in the notices of              
          deficiency were $183, $418, and $143, respectively, for 1990,               
          1991, and 1992.  At trial, the parties advised the Court that the           
          adjustments in the notices of deficiency involved other charities           
          as well as the contributions to the Cantare Chorale singers but             
          that the parties had reached a basis for settlement of the                  
          adjustments involving the other charities.  The deductions to the           
          Cantare Chorale singers represented the only remaining issue for            
          trial, those amounts being $141, $211, and $143, respectively,              
          for the 3 years at issue.  The Court further notes that, in the             
          stipulation of facts filed with the Court, the charitable                   
          contribution adjustment relating to the Cantare Chorale singers             

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