Richard C. and Hattie M. Martin - Page 2




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               Pursuant to separate notices of deficiency, respondent                 
          determined the following deficiencies and accuracy-related                  
          penalties:                                                                  
          Richard C. and Hattie M. Martin, Docket No. 18241-97:                       
                                                                                     
          Year               Deficiency           Sec. 6662(a)                        
          1992               $103,871               $20,774                           
          1993                 55,302                11,060                           
          1994                 35,991                 7,198                           

          William L. and Sylvia L. Martin, Docket No. 18247-97:                       
          Year               Deficiency            Sec. 6662(a)                       
          1992                $62,427                $12,485                          
          1993                 21,793                  4,359                          
          1994                 31,405                  6,281                          
               Following concessions by the parties, the primary remaining            
          issue to be resolved is whether Cola Performance Products, Inc. is          
          to be recognized as a distinct taxable entity during 1992, 1993,            
          and 1994, the consequence being the disallowance of certain                 
          business losses individually claimed by petitioners for each of             
          those years.1  Also at issue is whether petitioners are liable for          
          section 6662(a) accuracy-related penalties.                                 




               1    William L. Martin acknowledged that he was not involved           
          in the automotive crankshaft manufacturing business at issue, and           
          therefore he and his wife concede that they are not entitled to             
          the business losses they individually claimed. They request that            
          all business losses for the years in issue be attributed to                 
          Richard C. and Hattie M. Martin.                                            




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