Patrick E. Catalano - Page 3




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               Unless otherwise indicated, section references are to the              
          Internal Revenue Code in effect for the year in issue.  Rule                
          references are to the Tax Court Rules of Practice and Procedure.            
          Dollar amounts are rounded to the nearest dollar.                           
                                  FINDINGS OF FACT                                    
               Some of the facts are stipulated and are so found.  The                
          stipulation of facts and exhibits submitted therewith are                   
          incorporated herein by this reference.                                      
               Petitioner is an attorney who practiced law through his                
          wholly owned corporation, Patrick E. Catalano Professional Corp.            
          (petitioner’s law firm), during all relevant times.  The law firm           
          had offices in San Francisco and San Diego, California.  When               
          petitioner filed his petition in this case, he resided in San               
          Francisco, California.                                                      
               a.   Foreclosure of Petitioner’s Residence                             
               In 1988, petitioner purchased a residential condominium in             
          San Francisco, California (petitioner’s residence), for                     
          $1,800,000.  Wells Fargo Bank (Wells Fargo) financed $1,400,000             
          of the purchase price, secured by a lien on petitioner’s                    
          residence.  Petitioner ceased making payments of either interest            
          or principal on the Wells Fargo note as of June 1, 1994.                    
               In July 1994, petitioner and his law firm each filed a                 
          voluntary petition for bankruptcy under chapter 11 in the U.S.              
          Bankruptcy Court for the Northern District of California                    
          (bankruptcy court).  At the time petitioner filed his bankruptcy            





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