-2-
After concessions,2 the primary issue for decision is
whether Charles T. Wickersham (Mr. Wickersham) is liable for the
fraud penalty pursuant to section 6663(a). If we so find, we
must decide whether there is a deficiency for 1989.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
their petition, petitioners, husband and wife, resided in Orange,
Texas.
Mr. Wickersham's Businesses
In September 1988, Elco International, Inc. (Elco), was
incorporated. Elco purchased and operated a grain elevator in
Houston, Texas. Mr. Wickersham and Lester Winfree (Mr. Winfree)
were two of the four owners and directors of Elco.
During 1989, Mr. Wickersham owned and operated a Ford-
Lincoln-Mercury dealership, an insurance company, and a leasing
company. He also was involved in commercial property development
and owned 50 percent of a landholding company.
The Peveto
The Peveto Grain Elevator (the Peveto) is located in Orange,
Texas. In 1985, G & B Products purchased the Peveto and
converted it from a grain elevator into a grinding facility that
2 Respondent concedes that Sandra J. Wickersham is not
liable for the deficiency or the fraud penalty pursuant to sec.
6663 for 1989.
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