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amounts and for the years set forth above. We hold that they are
liable with one exception stated herein.
3. Whether petitioners William and Victoria McCurley,
pursuant to section 6661(a), are liable for an addition to tax
for a substantial understatement with respect to their 1988
return. We hold that they are liable.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
William and Victoria McCurley, husband and wife, resided in
Kennewick, Washington, at the time their petitions were filed.
Robert and Gayle Hall, husband and wife, resided in Yakima,
Washington, at the time their petition was filed. Messrs.
McCurley and Hall each owned automobile dealerships at all
relevant times. Mr. McCurley owned 100 percent of Bill McCurley
Chevrolet, Inc., and McCurley Pontiac, Inc. Mr. Hall owned 100
percent of Sunfair Chevrolet, Inc., and 75 percent of Greenway
Auto Plaza, Inc.
Each dealership offered financing to prospective customers.
The dealership, as an agent for an insurance company, offered
credit life and/or credit health insurance policies to customers
who financed their purchases through the dealership. The
dealership retained as compensation a portion of the premium due.
The policies provided that the insurer would make payments on the
dealership loan in the event the insured became disabled and
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