Frederick H. Jackson III and Pamela S. Jackson - Page 3

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          all Rule references are to the Tax Court Rules of Practice and              
                                  FINDINGS OF FACT                                    
               Some facts have been stipulated and are so found.  The                 
          stipulation of facts, with attached exhibits, is incorporated               
          herein by this reference.                                                   
               At the time of filing the petition, petitioners resided in             
          Wellington, Florida.                                                        
          The Corporation                                                             
               The corporation in question is Palm Beach Furniture Co.,               
          Inc., a Florida corporation (the corporation).  The corporation             
          is a calendar-year taxpayer.                                                
          The Bank                                                                    
               Monroe Bank and Trust (the bank) is an institution whose               
          address is in Monroe, Michigan.                                             
          The Loan Agreement                                                          
               By agreement dated October 28, 1994 (the loan agreement),              
          the bank agreed to lend the corporation $1.2 million (the loan).            
          Among other things, the loan agreement provides that the term of            
          the loan is 6 years, the interest rate is 8 percent, and                    
          approximately $250,000 of principal will be repaid during the               
          loan term (leaving a principal balance of $947,835.50 to be paid            
          at maturity).  The loan agreement also provides:                            

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