Eddie Cordes, Inc., et al. - Page 4




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          Cordes’s) income and, if properly included in Mr. Cordes’s                  
          income, whether that interest is income from self-employment;               
               3)   whether CFC may properly deduct from income                       
          repossession costs in 1994 and 1995;                                        
               4)   whether any of the petitioners are liable for the                 
          accuracy-related penalty pursuant to sec. 6662(a) for 1994 or               
          1995; and                                                                   
               5)   whether CFC and Mr. Cordes are liable for the fraud               
          penalty pursuant to sec. 6663(a) for 1994 or 1995.                          
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated.  The stipulation of            
          facts and the two supplemental stipulations of facts are                    
          incorporated herein by this reference, except as specifically               
          noted below.  At the time the petitions in these cases were                 
          filed, ECI’s principal place of business was in Lawton, Oklahoma;           
          Eddy Ben and Ellen K. Cordes resided in Lawton, Oklahoma; Joseph            
          P. and Jean Ann Richard resided in Lawton, Oklahoma; John J. and            
          Sue E. Cordes resided in Austin, Texas; and Edmund J. and June J.           
          Cordes (the Cordeses) resided in Lawton, Oklahoma.  Eddy Ben                
          Cordes, Jean Ann Richard, and John Cordes are the Cordeses’                 
          children.  We refer to the Cordeses together with their children            
          as the Cordes family.                                                       
          I.   Corporate Ownership                                                    
               ECI was incorporated in Oklahoma in January 1963 as an                 
          authorized dealership for Jeep-Eagle vehicles.  CFC was                     
          incorporated in January 1964 and operated mainly to finance new             





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