Christopher K. and Brenda M. Cox, et al. - Page 4




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          indebtedness owed by Cox Tomato to them (hereinafter referred to,           
          in the aggregate, as basis in Cox Tomato) to deduct their                   
          respective shares of the ordinary losses generated by Cox Tomato            
          during the years at issue;                                                  
               (2) whether Deborah may reduce the gross income she derived            
          from her use of a corporate automobile to reflect that she used             
          the automobile, in part, for business and that she reimbursed Cox           
          Tomato for some of her personal use; and                                    
               (3) whether Christopher and Brenda and Gregory and Linda are           
          liable for the accuracy-related penalty imposed by section                  
          6662(a) for 1994, and whether Robert and Deborah are liable for             
          the accuracy-related penalty imposed by section 6662(a) for 1995.           
                                  FINDINGS OF FACT                                    
          I.   Background                                                             
               Some of the facts have been stipulated and are so found.  We           
          incorporate the stipulation of facts into these findings by this            
          reference.                                                                  
               On the date the petitions were filed, Christopher and Brenda           
          resided in Edmond, Oklahoma; Gregory and Linda resided in                   
          Oklahoma City, Oklahoma; and Robert and Deborah resided in                  
          Ardmore, Oklahoma.  Christopher, Gregory, and Deborah                       
          (collectively referred to as petitioner shareholders) are                   
          siblings.                                                                   








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