Char-Lil Corporation - Page 10

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             for sale with a real estate agent, Mr. Bill Clements, and                
             sold the property on May 1, 1986.                                        
                  Petitioner paid no dividends during any of the years                
             in issue.  Petitioner paid no dividends after the close of               
             any of the taxable years in issue that could be eligible                 
             for the election in section 563(b).  Finally, petitioner                 
             did not make a consent dividend pursuant to section 565                  
             during any of the years in issue.                                        
                  For Federal income tax purposes, petitioner computed                
             taxable income using the cash receipts and disbursements                 
             method of accounting and the calendar year.  Petitioner                  
             filed timely returns on Form 1120, U.S. Corporation Income               
             Tax Return, for each of the years in issue, except for the               
             return for 1989, which was due on September 15, 1990, but                
             was not filed until August 12, 1991.                                     
                  Petitioner's returns for 1989 through 1994 report the               
             following income, deductions, and taxable income:                        

















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