Dennis C. Gandy - Page 4

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               (10) whether petitioners are liable for the additions to tax           
          under section 6661 for 1985 through 1987; and                               
               (11) whether Mr. Gandy is liable for an addition to tax                
          under section 6661 for 1988.                                                
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the exhibits attached thereto are              
          incorporated herein by this reference.  Petitioners resided in              
          Ben Wheeler, Texas, at the time they filed their petitions in               
          these cases.  During 1985 through 1989, petitioners were                    
          residents of Van Zandt County, Texas.                                       
               Petitioners were married on August 14, 1970.  Carolyn S.               
          Gandy (Mrs. Gandy) attended high school and completed the 10th              
          grade prior to marrying Mr. Gandy.  Mr. Gandy received a                    
          bachelor’s degree in management in 1971 from the University of              
          Texas at Austin.  Petitioners were divorced on June 14, 1988.               
          Mrs. Gandy moved back into the marital residence in 1991;                   
          however, petitioners remain divorced.                                       
               Burnice Gandy is Mr. Gandy's father.  In 1947, Burnice Gandy           
          received a disability discharge from the military.  From that               
          time,  Burnice Gandy's income consisted almost exclusively of               
          military disability and Social Security benefits.                           
          The Nursery                                                                 
               Petitioners established the nursery in 1972.  The nursery              
          property is located 5 miles south of Van, Texas.  Petitioners'              

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