Robert A. Stanford and Susan Stanford - Page 2

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               SWIFT, Judge:  Respondent determined a deficiency in, an               
          addition to tax on, and an accuracy-related penalty on                      
          petitioners' 1990 joint Federal income tax as follows:                      

                                                  Accuracy-Related                    
                              Addition to Tax     Penalty                             
               Deficiency     Sec. 6651(a)(1)     Sec. 6662(a)                        
               $423,531       $101,585            $84,706                             

               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for 1990, and all Rule                  
          references are to the Tax Court Rules of Practice and Procedure.            
          All references to petitioner are to Robert A. Stanford.                     
               The issues for decision are whether subpart F income of a              
          controlled foreign corporation may be reduced by deficits in                
          earnings and profits of a controlled foreign sister corporation             
          and whether subpart F income of a controlled foreign corporation            
          may be reduced by deficits in earnings and profits of a                     
          controlled foreign parent corporation.                                      

                                  FINDINGS OF FACT                                    
               Many of the facts have been stipulated and are so found.               
          During the year in issue, petitioners were U.S. citizens and                
          resided in Houston, Texas.                                                  
               In the mid-1980's, favorable laws in the crown colony of               
          Montserrat, British West Indies, made it relatively easy and                
          profitable for individuals to establish and to operate private              





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