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(2) whether petitioners Milo and Sarah Chapman and David and
Gladys Christie received early distributions from the Plan in
1988 and 1989 and therefore are liable under section 72(t) for
the 10-percent additional tax for early distributions;
(3) whether petitioners Milo and Sarah Chapman and David and
Gladys Christie constructively received interest income in 1989
from the payments by Dura-Craft, Inc. (Dura-Craft), and
Springbrook Marketing (Springbrook) to the Plan;
(4) whether petitioners David and Gladys Christie received
constructive dividends in 1989 from the loan repayments by both
Dura-Craft and Springbrook to the Plan in amounts greater than
those actually owed to the individual petitioners; and
(5) whether the 5-percent processing fees charged by
Northwest Purchasing, Inc., were allowable as a part of Dura-
Craft's cost of goods sold for fiscal years ending October 31,
1988 and 1989.
Background
These consolidated cases were submitted without a trial
pursuant to Rule 122. The stipulation of facts and the attached
exhibits are incorporated by this reference, and the facts
contained therein are found accordingly. Petitioners Milo
Chapman and Sarah Chapman (collectively hereinafter referred to
as the Chapmans) resided in Newberg, Oregon, at the time the
petition was filed in docket No. 20342-94, and petitioners David
Christie and Gladys Christie (collectively hereinafter referred
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