Jacob and Chana Pinson, et al. - Page 5




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          Zeilers only to the extent necessary to comprehend the underlying           
          context.  The corporate petitioner shall be referred to as                  
          Deitsch Plastic Company, Inc., or DPC.                                      
               After concessions, the issues remaining for decision are:              
               (1) The proper tax treatment of payments made directly from            
          Flocktex Industries, Ltd. (FIL), an Israeli corporation, to                 
          certain of petitioners, and of foreign taxes paid thereon;                  
               (2) the proper tax treatment of payments made from FIL to              
          Deitsch Plastic Partners (DPP) and reported by certain of                   
          petitioners as their distributive shares of partnership income;             
          and                                                                         
               (3) the applicability of accuracy-related penalties pursuant           
          to section 6662(a) for negligence, intentional disregard of rules           
          or regulations, and/or substantial understatement of income tax.            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulations of the parties, with accompanying exhibits, are            
          incorporated herein by this reference.                                      
          The Deitsch Family                                                          
               The individuals involved in these consolidated cases are all           
          members of the Deitsch family.  David Deitsch is the patriarch of           
          the family, and Sara is his wife.  Mordecai Deitsch, Joseph                 
          Deitsch, Rachel Sandman, Ella Zeiler, and Chana Pinson are the              
          children of David Deitsch.  Joshua Sandman, B. Mayer Zeiler, and            






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