Char-Lil Corporation - Page 15

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             activities.  Respondent's notice of deficiency states as follows:        


                  The total deductions of $98,183.00 shown on your                    
                  return are reduced by $39,186.00 because to the                     
                  extent that the total deductions from passive                       
                  activities exceed the total income from such                        
                  activities for the tax year, the excess is not                      
                  allowed as a deduction for that year.  Therefore,                   
                  your taxable income for the taxable year ended                      
                  December 31, 1992 is increased $39,186.00.                          
                  The total deductions of $105,470.00 shown on your                   
                  return are reduced by $51,416.00 because to the                     
                  extent that the total deductions from passive                       
                  activities exceed the total income from such                        
                  activities for the tax year, the excess is not                      
                  allowed as a deduction for that year.  Therefore,                   
                  your taxable income for the taxable year ended                      
                  December 31, 1993 is increased $51,416.00.                          

                  Respondent determined that petitioner is liable for                 
             the additions to tax under section 6651(a)(1) for 1989                   
             because petitioner's 1989 return was not timely.                         
             Petitioner does not challenge this adjustment.  Finally,                 
             respondent determined that petitioner is liable for the                  
             addition to tax under section 6662(a) for the years in                   
             issue because of a substantial understatement of tax with                
             respect to each of those years.                                          

                                       OPINION                                        
             Personal Holding Company Tax                                             
                  The first issue for decision is whether petitioner                  
             is subject to the personal holding company tax imposed by                





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