Raymond K. and Minerva R. Mason - Page 5

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          would have been at the applicable Federal rate (AFR) under                  
          section 7872(e)(2) for 1987 and 1988.  Of petitioners' repayments           
          to RSI, KPMG calculated that $728,098 and $214,065 ought to have            
          been applied to reduce the outstanding principal on the loans for           
          1987 and 1988, respectively, and $111,604 and $167,569 should               
          have been allocated to interest at the AFR for those same years.            
               Respondent timely issued a statutory notice of deficiency on           
          February 16, 1996.  Among other things, respondent adjusted                 
          petitioners' income for the relevant tax years to reflect                   
          dividend income from RSI pursuant to section 7872.  (Respondent             
          adjusted RSI's income on its Forms 1120 for 1987 and 1988 to                
          reflect interest income in the amounts calculated by KPMG.)                 
          Respondent further adjusted petitioners' itemized deductions to             
          allow for a partial deduction for the interest respondent deemed            
          paid to RSI by petitioners for the years in question.  Respondent           
          allowed petitioners a full deduction for interest expenses                  
          identified from "investment sources" in the KPMG analysis, and a            
          partial deduction for interest expenses identified from "personal           
          sources", in accordance with section 163.                                   
                                     Discussion                                       
               We must decide whether respondent properly imputed dividends           
          to petitioners in 1987 and 1988 under section 7872 where no                 
          evidence indicates that interest had accrued or was otherwise               
          paid on the loans in those years.  (Petitioners concede that                
          respondent's adjustments to RSI's income and to petitioners'                




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