Unilever Superannuation Trustees Limited - Page 3




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          Returns for U.S. Source Income of Foreign Persons, and 1991 and             
          1993 Forms 1042S, Foreign Person's U.S. Source Income Subject to            
          Withholding.  (The agents and financial intermediaries had                  
          previously issued the Fund copies of the Forms 1042S.)  These               
          forms were not required to, and did not, list the taxpayer                  
          identification number of either the Fund or petitioner.  These              
          forms also were not signed by either of these two.  Forms 1042              
          and 1042S make no provision for signature by the persons from               
          whom taxes are withheld.                                                    
               On June 8, 1992, petitioner submitted to respondent a 1991             
          Form 990-T, Exempt Organization Business Income Tax Return,                 
          claiming a refund of $867,222 in income taxes.  Petitioner's                
          claim was based on its assertion that the Fund was a tax-exempt             
          organization under section 501(c)(5).  The information listed on            
          the 1991 Form 990-T included petitioner's name, address, and                
          employer identification number and its claim that it was entitled           
          to a $867,222 refund for "ERRONEOUS WITHHOLDING".  On or about              
          April 15, 1993, respondent refunded to petitioner the $867,222              
          amount that had been withheld for 1991.                                     
               On April 28, 1995, petitioner submitted to respondent a 1993           
          Form 990-T, claiming a refund of $606,120 in income taxes.                  
          Petitioner's claim was based on its assertion that the Fund was a           
          tax-exempt organization under section 501(c)(5).  The information           
          listed on the 1993 Form 990-T included petitioner's name,                   





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