Leema Enterprises, Inc. - Page 2




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               Gary D. Kallevang, Wilton A. Baker, Kim A. Palmerino, and              
          William H. Quealy, Jr., for respondent.                                     


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               JACOBS, Judge:  These cases were assigned to Chief Special             
          Trial Judge Peter J. Panuthos pursuant to the provisions of section         
          7443A(b)(4) and Rules 180, 181, and 183.2  The Court agrees with            
          and adopts the opinion of the Special Trial Judge, which is set             
          forth below.                                                                
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               PANUTHOS, Chief Special Trial Judge:  By timely notices of             
          deficiency, respondent determined that petitioners in these                 
          consolidated cases are liable for deficiencies, additions to tax,           
          and penalties as follows:                                                   
                     Leema Enterprises, Inc., docket No. 39476-85                     
                                        Additions to Tax                              
               Year              Deficiency       Sec. 6653(a)(1)                     
               6/30/80        $432,667          $21,633                               
               6/30/81        1,100,399           55,020                              

                     Leema Enterprises, Inc., docket No. 4797-86                      
                                        Addition to Tax                               
               Year              Deficiency       Sec. 6653(a)(1)                     
               6/30/82   $785,688          $39,284                                    

               2    All section references are to the Internal Revenue                
          Code, unless otherwise indicated.  All Rule references are to the           
          Tax Court Rules of Practice and Procedure.                                  


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