Reginald and Ronda Charlson - Page 2




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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               FOLEY, Judge:  By notice dated April 21, 1999, respondent              
          determined the following deficiencies relating to petitioners’              
          Federal income taxes:                                                       
                  Reginald and Ronda Charlson, docket No. 12840-99                    
                         Year                     Deficiency                          
                         1994                     $125,027                            
                         1995                     26,775                              
                         1996                     30,058                              
                 Great American Stageline, Inc., docket No. 12905-99                  
                         Year                     Deficiency                          
                         1995                     $25,749                             
                         1996                     38,652                              
                         1997                     841                                 
               Unless otherwise indicated, all section references are to              
          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.  After concessions, the issue for decision is whether            
          any petitioner is entitled to an investment tax credit (ITC) that           
          was carried forward from 1985.                                              
                                  FINDINGS OF FACT                                    
               When their respective petitions were filed, Reginald and               
          Ronda Charlson resided in Westlake Village, California, and Great           
          American Stageline, Inc. (Great American), had its principal                
          place of business in Newbury Park, California.                              
               The Charlsons owned two corporations, Great American, a C              
          corporation, formed in 1974, and C & C Investments, Inc. (C & C),           





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