ABC Rentals of San Antonio, Inc. - Page 3

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          ABC Rentals of San Antonio, Inc. v. Commissioner, 142 F.3d at               
          1211.                                                                       
                                  FINDINGS OF FACT                                    
               This case was submitted without a trial pursuant to Rule               
          122.  The findings of fact are set forth in ABC Rentals I and are           
          incorporated herein by this reference.  The stipulation and                 
          exhibits are also incorporated herein by this reference.  For               
          convenience, we shall repeat those facts as necessary to clarify            
          the ensuing discussion.  We also set forth below certain                    
          supplementary findings of fact that were not set forth in our               
          prior opinion but which are based on the record of the instant              
          case and are relevant to issues decided on remand.                          
               The individual petitioners petitioned this Court contesting            
          respondent's determinations of deficiencies in their Federal                
          income tax as follows:                                                      
          ABC Rentals of San Antonio, Inc.--Docket No. 20689-91                       
               Tax Period Ended              Deficiency                               
                    5/31/87                  $7,404.90                                
          David R. Peters and Diana L. Peters--Docket No. 20690-91                    
               Tax Period Ended              Deficiency                               
                    12/31/87                 $572                                     
                    12/31/88                 833                                      

          John P. Parsons and Melba R. Parsons--Docket No. 20691-91                   
                                                  Additions to Tax                    
          Tax Period Ended         Deficiency        Sec. 6661                        
               12/31/87            $11,028             $2,757                         
               12/31/88            8,095               2,024                          


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