Anthony W. Jorgenson and Florence A. Jorgenson - Page 3




                                        - 3 -                                         
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, the supplemental stipulation of facts,            
          and the attached exhibits are incorporated herein by this                   
          reference.  At the time they filed their petition, petitioners              
          resided in Nacogdoches, Texas.                                              
               Petitioners both practice medicine.  During the years in               
          issue, Mr. Jorgenson worked full time as an orthopedic surgeon,             
          while Mrs. Jorgenson practiced full time as a radiologist.                  
               Together, petitioners reported the following amounts as                
          wages and partnership income from their medical practices during            
          the years in issue:                                                         

                                   Petitioners’ Wages and                             
                                   Partnership Income                                 
                    Taxable Year      From Medical Practices                          
                    1992                 $982,004                                     
                    1993                865,193                                       
                    1994                839,715                                       

               Petitioners were raised in rural communities.  Mr. Jorgenson           
          grew up on a 400-acre farm in Minnesota.  On the Minnesota farm,            
          Mr. Jorgenson’s parents maintained dairy and beef cattle, hogs,             
          and chickens.  In addition, Mr. Jorgenson’s father planted corn             
          and soybeans.  Mr. Jorgenson’s father gave him part of the                  
          family’s calves, which he raised and eventually sold.  Mrs.                 
          Jorgenson was born on a 750-acre ranch near Austin, Texas.  On              
          the farm, her father raised various crops.  Her father also gave            





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