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FINDINGS OF FACT2
Petitioners Albert J. Henry and Mary Henry resided in San
Diego, California, and Scarborough, North Yorkshire, England,
respectively, at the time of filing petitions in these cases.
Petitioners' 1982 joint Federal income tax return was prepared by
their accountant, Robert E. Douglas (Douglas), who signed it as
the preparer on April 15, 1983.
Albert J. Henry (Henry) has a bachelor of science degree in
civil engineering as well as a master's degree in business
administration. Between 1962 and 1968, Henry worked as a lending
officer at First National City Bank (First National) in New York
City. In that capacity, subject to approval, he reviewed and
prepared credit lines for businesses.
After his tenure with First National, Henry worked in Los
Angeles and New York City for firms that were members of the New
York Stock Exchange. In that regard, Henry prepared
institutional research reports on growth companies for use by
entities like mutual and pension funds, as well as banks.
Institutional reports are intended to cover a particular
company's products, what the projected growth rate might be, and
what sort of proprietary advantages the company might have.
These reports were designed to give money managers an idea of the
value of a company's stock. These reports do not incorporate
2 The parties' stipulation of facts and exhibits are
incorporated by this reference.
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