David K. Straight - Page 14

                                         14                                           
          $9,741 for 1991, and $4,354 for 1992, and accuracy-related                  
          penalties of $86,741 for 1990, $1,948 for 1991, and $871 for 1992           
          under section 6662.  Respondent determined that petitioner's                
          distributive share of ordinary income from Eagle for 1990, 1991,            
          and 1992 should be increased.  The notice of deficiency stated as           
          follows:                                                                    
                    It is determined that your distributable share of                 
               ordinary income from the small business corporation                    
               known as "Eagles Nest Homes" is $1,391,539 and $67,822                 
               for the taxable years ended December 31, 1990 and 1992                 
               and your distributable share of ordinary loss is                       
               $21,340 for the taxable year ended December 31, 1991                   
               rather than the loss amounts of $148,582 and $39,713                   
               for the taxable years ended December 31, 1990 and 1991                 
               and the amount of $54,188 for the taxable year ended                   
               December 31, 1992 as was claimed on your returns for                   
               those taxable years.  This determination is based on an                
               examination of the corporate return of "Eagles Nest                    
               Homes" for the taxable years ended December 31, 1990,                  
               1991 and 1992, which is summarized below.  A detailed                  
               report has been furnished to the tax matters partner                   
               (person) who should be contacted for additional                        
               information.  Accordingly, your taxable income for the                 
               taxable years ended December 31, 1990, 1991 and 1992 is                
               increased by the respective amounts of $1,540,121,                     
               $18,373 and $13,634.                                                   


















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