Eugene D. Lanier, Inc. - Page 2

                                        - 2 -                                         
                                 Docket No. 9146-93                                   
                                                      Addition to Tax                
               Tax Year            Deficiency          Sec. 6661(a)                   
               1987                $63,128             $22,734                        

                                 Docket No. 9171-93                                   
                                                      Addition to Tax                
               Tax Year            Deficiency          Sec. 6661(a)                   
               1987                $88,370             $22,093                        
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the year in issue.  All             
          Rule references are to the Tax Court Rules of Practice and                  
               After concessions, the issues remaining for decision are as            
          follows:  (1)  Whether the fair market value (FMV) of certain               
          real property sold to the Laniers by their wholly owned                     
          Corporation exceeded its purchase price; and (2) whether the                
          Laniers received a constructive dividend in the amount of $13,000           
          as a result of the Corporation's transfer of that sum to their              
          son's election campaign committee.                                          
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are found                   
          accordingly.  The stipulation of facts and attached exhibits are            
          incorporated herein by this reference.  The Corporation was                 
          domiciled in Youngsville, Louisiana, at the time it filed its               
          petition.  The Laniers were married and resided in Youngsville,             
          Louisiana, when they filed their petition.                                  

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