Charles C. Allen, III and Barbara N. Allen, et al. - Page 4




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          he was the husband of Judith M. Allen during 1995.  John R.                   
          Allen, Jr., was the husband of Susan S. Allen.  Warren L. Allen,              
          Jr., was the husband of Amantha S. Allen.  Each petitioner and                
          his wife (with the exception of Sally F. Allen) resided in                    
          Delaware when the petitions were filed.  Sally F. Allen was                   
          deceased at that time, and the executor of her estate was (and                
          is) John R. Allen, Jr.                                                        
               Allen Family Foods, Inc. (Foods), is an S corporation that               
          was incorporated under Delaware law.  Its business is the                     
          slaughtering, converting, and processing of chickens into                     
          ready-to-cook whole chickens and chicken parts for sale primarily             
          to retailers.  It computes its income and expenses using an                   
          accrual method of accounting and on the basis of a fiscal year                
          ending on the Saturday nearest April 30.  It filed a Form 1120S,              
          U.S. Income Tax Return for an S Corporation, for its fiscal years             
          ended in 1994 and 1995 (its 1994 and 1995 taxable years,                      
          respectively).                                                                
               Petitioners are descendants of Charles C. Allen, the founder             
          of the family poultry business, and they owned all of Foods’                  
          outstanding stock during its 1994 and 1995 taxable years.  The                
          number of the shares that they each owned and the percentage of               
          their respective ownership interests were as follows:                         










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