Raymond K. and Minerva R. Mason - Page 2

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               I.R.C., are sustained, subject to recomputation under                  
               Rule 155.                                                              


               Mike E. Jorgensen, for petitioners.                                    
               Charles Baer, for respondent.                                          


                                 MEMORANDUM OPINION                                   
               NIMS, Judge:  Respondent determined the following                      
          deficiencies, additions to tax, and accuracy-related penalty with           
          respect to the Federal income tax of petitioners, Raymond K. and            
          Minerva R. Mason, for the taxable years 1987, 1988, and 1989:               
                                   Additions to Tax      Penalty                      
          Year      Deficiency          Sec. 6661      Sec. 6662(a)                   
          1987      $38,236             $9,559              --                        
          1988      36,662              9,166               --                        
          1989      --                  --               1$5,927                      
          ______________                                                              
               1  This figure is equal to 20 percent of the underpayment of           
          tax previously assessed.                                                    

               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years at issue.  All            
          Rule references are to the Tax Court Rules of Practice and                  
          Procedure.                                                                  
               After concessions, the remaining issues for decision are:              
          (1) Whether petitioners received below-market demand loans from             
          their closely held corporation such that dividends may be imputed           
          to them in 1987 and 1988 in the amount of the forgone interest              
          pursuant to section 7872; and (2) whether petitioners are liable            




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