Sharon E. Backstrom, Harold J. and Zelma G. Barbret, Virginia Boland, John A. and Theresa A. Cislaghi, Estate of Roger W. Dornbrock, Gary E. and Beverly G. Engel, Hermann K. and Helen W. Enzmann, - Page 4

                                        - 4 -                                         

          Dornbrock claimed a Schedule E partnership loss and an investment           
          tax credit on their joint 1981 Federal income tax return from the           
          Pop Phonomasters program.  They also filed amended joint Federal            
          income tax returns for 1978, 1979, and 1980, claiming investment            
          tax credit carrybacks for those years arising out of the Pop                
          Phonomasters program.  The investment tax credits resulted in               
          Federal income tax refunds for each of these years.  On April 12,           
          1985, a notice of deficiency was issued to Roger W. Dornbrock and           
          Maryn J. Dornbrock, husband and wife, for all years involving the           
          Pop Phonomasters program.  In the notice of deficiency,                     
          respondent determined the following deficiencies in Federal                 
          income taxes and additions to tax:                                          

               Additions to Tax                                                       
                                            Sec.             Sec.                    
          Year     Deficiency                6653(a)           6659                   
               1978      $3,273.50           $163.68        $982.05                   
          1979       9,818.00                490.90         2,945.40                  
          1980       3,081.00                154.05         924.30                    

          These deficiencies arose solely from Roger W. Dornbrock's                   
          participation in the Pop Phonomasters program.4                             
               On July 11, 1985, a joint petition was filed on behalf of              
          approximately 35 petitioners who received notices of deficiency             
          as a result of their participation in the Pop Phonomasters                  

          4                                                                           
               Although adjustments were made in the notice of deficiency             
          to the Dornbrocks' income for 1981, no deficiency was determined            
          for that year.                                                              




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