James W. and Laura L. Keith - Page 3




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               (2) the reduction of net operating loss carryovers from                
          years preceding the years in issue to reflect income attributable           
          to contracts for deed executed in those prior years.                        
               Additionally, the parties have agreed that a third issue,              
          the availability of depreciation deductions for properties                  
          subject to such contracts for deed, is dependent upon and will be           
          resolved by our decision regarding petitioners’ accounting                  
          method.  The parties have stipulated the amounts to be allowed as           
          depreciation deductions in the event of a ruling either for                 
          petitioners or for respondent.                                              
               Unless otherwise indicated, all section references are to              
          sections of the Internal Revenue Code in effect for the years in            
          issue, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     
                                     Background                                       
               This case was submitted fully stipulated pursuant to Rule              
          122, and the facts are so found.  The stipulations of the                   
          parties, with accompanying exhibits, are incorporated herein by             
          this reference.  Petitioners resided in Moultrie, Georgia, during           
          each of the years in issue and at the time their petition was               
          filed in this case.                                                         
          Formation of Greenville Insurance Agency (GIA)                              
               Petitioner James W. Keith is a radiologist, and petitioner             
          Laura L. Keith is a dentist.  Mrs. Keith is also the owner of a             






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