Starvest U.S., Inc. - Page 2




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          17705-98, respondent moves to dismiss for lack of jurisdiction on           
          the grounds that petitioner, a corporation dissolved under State            
          law, did not have the capacity to initiate the subject litigation           
          and, if it had the capacity to do so, did not authorize the                 
          filing of the petitions with this Court.  In docket No. 1372-99,            
          respondent moves to dismiss for lack of jurisdiction on the                 
          grounds that the petition was not filed timely and is duplicative           
          of docket No. 17705-98.                                                     

                                  FINDINGS OF FACT                                    
               Some of the facts were stipulated.  Those facts and the                
          accompanying exhibits are so found and are incorporated herein by           
          reference.  Petitioner, a Florida corporation, had its principal            
          place of business at Tierra Verde, Florida, at the time the                 
          petitions were filed.                                                       
               Respondent determined the following deficiencies in                    
          petitioner's Federal income taxes, additions to tax, and                    
          penalties:                                                                  
















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