Gordon J. and Bonnie L. Schoof - Page 3

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          9490-96   Joe O. and Daurine M. Baker             3,002                     
          15341-96 Joseph P. and Genice Spetz               8,724                     
          15342-96 Robert C. and Mary D. Borman             16,462                    
          17606-96 Nurit Haramgaal                          11,405                    
          17607-96 John S. Husmann and Elinor C. MacKinnon    4,606                   
          1    A notice of deficiency was issued to Alice M. Johnson and her          
          husband Duaine E. Johnson.  Mr. Johnson died on Sept. 1, 1994.  An          
          estate was not opened for him.  Alice M. Johnson, as surviving              
          spouse, is the sole petitioner in docket No. 6617-96.                       
               Each of these 12 consolidated cases involves the following             
          transactions:  (a) A distribution from an individual retirement             
          plan, (b) an attempted tax-free rollover contribution of that               
          distribution to a newly established putative individual retirement          
          account trust, and (c) a purchase of a unit(s) (or fraction                 
          thereof) in a bus stop shelter program.  The issue for decision is          
          whether the rollover qualifies for tax-free treatment.  Resolution          
          of this issue depends in part upon whether the trustee of the               
          putative individual retirement account trust is an eligible                 
          trustee.                                                                    
               Unless otherwise indicated, all section references are to the          
          Internal Revenue Code in effect for the year in issue, and all Rule         
          references are to the Tax Court Rules of Practice and Procedure.            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.  The          
          stipulation of facts and attached exhibits are incorporated herein          
          by this reference.                                                          




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