Neil M. Baizer - Page 3

          for an addition to tax under section 6651(a)(1) for failure to              
          file excise tax returns; and (4) whether respondent had authority           
          to issue a notice of deficiency in regard to a prohibited                   
          transaction when the Department of Labor had previously entered             
          into a stipulation of consent judgment with petitioner.                     
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein.  Neil M. Baizer (petitioner) resided in Los            
          Angeles, California, when the petition was filed.                           
               Cohen & Baizer Accountancy Corp. (the Corporation) is a                
          California corporation that was incorporated on August 4, 1980.             
          Petitioner and M. Richard Cohen were officers and directors of              
          the Corporation, and together they were the majority shareholders           
          of the Corporation.  The Corporation has been inactive since                
          December 1987.  Although its corporate charter was suspended by             
          the California secretary of state's office on December 1, 1989,             
          the Corporation has not been dissolved.                                     
               Effective February 1, 1981, the Corporation adopted, for the           
          benefit of its employees and their beneficiaries, the Cohen &               
          Baizer Accountancy Corporation Defined Benefit Pension Plan and             
          associated Trust (collectively, the Plan).  At all times                    
          relevant, the Plan was a qualified plan and an exempt trust                 
          within the meaning of sections 401(a) and 501(a).  Both the                 
          Corporation and the Plan maintained tax years ending January 31.            

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