Robert L. Boehm and Winona J. Mowrey - Page 3




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               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code as in effect for the years in issue,              
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
                                     Background                                       
               The parties have stipulated some of the facts, which are so            
          found.  The stipulated facts and the accompanying exhibits are              
          incorporated herein by this reference.  When they filed their               
          petition, the individual petitioners were married and resided in            
          Dallas, Texas.                                                              
              Crestmark is a corporation formed under the State laws of              
          Texas.  When it filed its petition, Crestmark’s principal office            
          was located in Dallas, Texas.                                               
                Since 1976, Winona Mowrey (Mowrey) has been employed in the           
          mortgage banking business as a loan officer.  During the year in            
          issue, Mowrey was employed as loan officer and manager of a                 
          branch office of Fort Worth Mortgage Corp. and Colonial Savings,            
          F.A. (Fort Worth Mortgage), and reported wage income of                     


               1(...continued)                                                        
          (1991); Money v. Commissioner, 89 T.C. 46, 48 (1987); Grossman v.           
          Commissioner, T.C. Memo. 1996-452, supplemented by T.C. Memo.               
          1997-451, affd. __ F.3d __ (4th Cir., June 28, 1999).  On brief,            
          respondent indicates that because of a miscalculation, the amount           
          of imputed interest income was overstated in the notice of                  
          deficiency.  We expect respondent to give Crestmark the benefit             
          of the revised computation in the Rule 155 computation, and in              
          accordance with representations in respondent’s trial memorandum            
          and opening statements at trial, to make appropriate adjustments            
          to Crestmark’s taxable income with respect to the income                    
          reassigned from Crestmark to the individual petitioners.                    



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