ABC Rentals of San Antonio, Inc. - Page 5

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               On January 27, 1992, these cases were consolidated.  These             
          consolidated cases were submitted without a trial pursuant to               
          Rule 122.                                                                   
               At the time the petitions were filed in these cases,                   
          Guaranteed and ABC (hereinafter sometimes collectively referred             
          to as the Entities or individually referred to as an Entity) were           
          corporations incorporated in the State of Texas with their                  
          principal offices located in Wichita, Kansas.  During the taxable           
          periods in controversy, Guaranteed and ABC were accrual basis               
          taxpayers.                                                                  
               For the fiscal year ending May 31, 1987, ABC timely filed              
          its Federal corporate income tax return.  ABC timely filed a                
          valid subchapter S election, and the election was granted                   
          effective June 1, 1987.  Guaranteed timely filed its Federal                
          corporate income tax return for an S corporation for the calendar           
          year ending 1987, and ABC timely filed its Federal corporate                
          income tax return for an S corporation for the short taxable                
          period ending December 31, 1987.  Guaranteed and ABC timely filed           
          their Federal corporate income tax returns for S corporations for           
          the calendar year 1988.                                                     
               Guaranteed and ABC operated commercial enterprises which               
          rented consumer durables (appliances, furniture, televisions,               
          stereos, and video cassette recorders) under rent-to-own leases             
          to individuals.  Both Entities have been in the rent-to-own                 
          business for a number of years.  During the tax periods in                  
          controversy, Guaranteed and ABC estimated that the total gross              


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