French E. Hickman and Janice C. Hickman - Page 7

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          Bank's common stock remained as one share of common stock of the            
          resulting national bank, and each share of National Bank of                 
          Harrah's common stock was exchanged for one-seventh of a share of           
          Midwest Bancshares common stock.                                            
               In their returns for 1991, 1992, and 1993, petitioners                 
          claimed total investment interest expenses of $330,581, $221,697,           
          and $149,034, respectively.  Of those total amounts, petitioners            
          reported in the Forms 4952 (Investment Interest Expense Deduc-              
          tion), which they included with their returns for 1991, 1992, and           
          1993, respectively, that (1) $323,088 was "Investment interest              
          expense paid or accrued in 1991", and $7,493 was "Disallowed                
          investment interest expense from 1990 Form 4952, line 23";                  
          (2) $47,824 was "Investment interest expense paid or accrued in             
          1992", and $173,873 was "Disallowed investment interest expense             
          from 1991 Form 4952, line 5"; and (3) $49,445 was "Investment               
          interest expense paid or accrued in 1993", and $99,589 was                  
          "Disallowed investment interest expense from 1992 Form 4952, line           
          5".  Included in the $323,088 of investment interest expense                
          which petitioners claimed in their 1991 Form 4952 they paid or              
          accrued during 1991 was the 1991 interest payment of $268,027.48            
          that petitioner made as part of the 1991 settlement to correct              
          the 1982 plan loan prohibited transaction.                                  
               Because of limitations prescribed by section 163(d)(1) on              
          the deductible amount of investment interest, petitioners de-               





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