KTA-Tator Inc. - Page 2

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                                       OPINION                                        
               FOLEY, Judge:  By notice dated September 27, 1995,                     
          respondent determined deficiencies in petitioner's Federal income           
          taxes as follows:                                                           
                         Year                     Deficiency                          
                         1992                     $10,443                             
                         1993                     1,828                               
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.  The issue for decision is whether petitioner,                   
          pursuant to section 7872, has interest income from loans it made            
          to its shareholders.  We hold that it does.                                 
                                     Background                                       
               The facts have been fully stipulated under Rule 122 and are            
          so found.  At the time the petition was filed, petitioner's                 
          principal place of business was in Pittsburgh, Pennsylvania.                
               During the years in issue, petitioner provided various                 
          services within the coatings industry, including consulting,                
          engineering, inspection, and lab analysis.  Kenneth B. Tator is             
          the president of petitioner, and he and his wife (the Tators) are           
          its sole shareholders.                                                      
               In 1991, the Tators began two construction projects.  The              
          first project involved the expansion of petitioner's Pittsburgh             




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