Reginald Maurice Wise and Shannon Rae Wise - Page 4

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          8.  Whether Eicher may include in gross income $73,122 of                    
          interest related to loans he made to Hersco.  We hold that he may            
          not.                                                                         
               9.  Whether Wise and Eicher had enough basis in WRI on July             
          31, 1988, to deduct their shares of WRI's net operating loss.  We            
          hold that they did not.                                                      
          10.  Whether the Wises are liable for the addition to tax                    
          for negligence under section 6653(a).  We hold that they are.                
          11.  Whether the Wises are liable for the addition to tax                    
          for substantial understatement of tax under section 6661.  We                
          hold that they are if they substantially underpaid tax for 1988.             
               12.  Whether Eicher is liable for the addition to tax for               
          substantial understatement of tax under section 6661.  We hold               
          that he is if he substantially underpaid tax for 1988.                       
               Section references are to the Internal Revenue Code in                  
          effect for the year in issue.  Rule references are to the Tax                
          Court Rules of Practice and Procedure.                                       
                                   FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.                
          A.   Petitioners                                                             
               The Wises lived in Florida and Eicher lived in Brazil when              
          they filed the petitions in these cases.  Eicher is a U.S.                   
          citizen, but has lived in Brazil since the early 1950's.  He                 
          worked for the Unisys Corporation until 1992.  Eicher used the               
          address, "c/o 938 Wald Road, Orlando, Florida", on his petition.             




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