Gabriel M. Daya, et al. - Page 3




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               6.  Whether Gabriel is entitled to property tax deductions             
          in taxable years 1995 and 1996 in excess of those allowed by                
          respondent.  We hold that he is not.                                        
               7.  Whether Morhaf is entitled to a property tax deduction             
          in taxable year 1995.  We hold that he is not.                              
               8.  Whether the underpayment of tax required to be shown on            
          Gabriel’s 1995 and 1996 Federal income tax returns is due to                
          negligence or to disregard of rules or regulations.  We hold that           
          it is.                                                                      
               9.  Whether the underpayment of tax required to be shown on            
          Morhaf’s 1995 Federal income tax return is due to negligence or             
          disregard of rules or regulations.  We hold that it is.                     
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by reference.                                           
                                  FINDINGS OF FACT                                    
               At the time petitions were filed for his 1995 and 1996                 
          taxable years, Gabriel resided in Fremont, California.  At the              
          time the petition was filed for his 1995 taxable year, Morhaf               
          resided in Foster City, California.                                         
               Petitioners are brothers who in August of 1983 emigrated from          
          Syria to the United States with their family (the Mahmoud Daya              
          family).  Members of the Mahmoud Daya Family include petitioners'           
          father, Mahmoud Gabriel Daya (Mahmoud), petitioners' mother, Laila          






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