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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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