Abdul Hafiz and Rawnaq A. Hafiz - Page 2

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          the amount of debt for which they and the corporation were the              
          primary obligors.                                                           
                                  FINDINGS OF FACT1                                   
               Petitioners Abdul and Rawnaq Hafiz are husband and wife and            
          timely filed joint Federal income tax returns for the years 1989            
          and 1990.  Petitioners resided in North Jackson, Ohio, at the               
          time they filed their petition in this case.                                
               In the late 1970's, petitioner Abdul Hafiz (Mr. Hafiz)                 
          entered into a partnership to invest in the motel business.  The            
          partnership owned and operated a Days Inn in Monroe, Ohio.  In              
          1984, the partnership began experiencing severe financial                   
          difficulties.  Mr. Hafiz decided to purchase the motel from the             
          partnership in the hopes of turning it into a profitable                    
          enterprise.                                                                 
               In 1985, Mr. Hafiz decided to form Family Motels, Inc.                 
          (Family Motels), a corporation that elected to be treated as a              
          "small business corporation" under subchapter S.  Mr. Hafiz was a           
          90-percent shareholder of Family Motels, and his family members             
          held the remaining shares.  Family Motels was organized to                  
          acquire and manage motels.                                                  
               At the time of incorporation, it was necessary to borrow               
          funds to purchase the Days Inn in Monroe.  Mr. Hafiz met with               


               1 The stipulation of facts and the attached exhibits are               
          incorporated by this reference.                                             




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