Antonio and Joyce Rosario - Page 2

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               The parties submitted this case fully stipulated pursuant to           
          Rule 122.1  The stipulation of facts and the attached exhibits              
          are incorporated herein by this reference.  At the time the                 
          petition was filed, petitioners resided in Marion, Ohio.                    
               Petitioner Antonio Rosario (hereinafter, petitioner) is an             
          orthopedic surgeon.  The hospital is located in Springfield,                
          Tennessee.  To induce petitioner to practice in the Springfield             
          area, petitioner and the hospital executed a Professional                   
          Practice Agreement (the practice agreement) on September 30,                
          1992.  The practice agreement provided, in part:                            
                    Income Guarantee.  Hospital guarantees that,                      
               during the term of this Agreement, Physician’s gross                   
               income (defined as collected professional fees) will                   
               not be less than Thirty-Three Thousand Three Hundred                   
               Thirty-Four Dollars ($33,334.00) per month.  To the                    
               extent that Physician’s gross income in any month                      
               during the term of this Agreement is less than                         
               $33,334.00, the Hospital will pay Physician by the                     
               tenth day of the closing of the Physician’s books for                  
               that month any amount sufficient to raise Physician’s                  
               income for that month to $33,334.00 (such payment by                   
               Hospital, will be referred to as a “Gross Guarantee                    
               Payment”).  If, during any month of the term of this                   
               Agreement, Physician’s income is greater than                          
               $33,334.00, Physician will pay to Hospital by the tenth                
               day after the closing of Physician’s books for the                     
               month, the excess over $33,334.00, to the extent                       
               necessary to reimburse hospital for Gross Guarantee                    
               Payments previously paid.  Such payments by Physician                  
               will be made to the Hospital during the term of this                   

               1  All section references are to the Internal Revenue Code             
          in effect for the year in issue, and all Rule references are to             
          the Tax Court Rules of Practice and Procedure.  Amounts are                 
          rounded to the nearest dollar.                                              

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