T.P. and Najieh R. Crigler - Page 14




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          1958).  Second, the Instructions to Forms 1120 and 1120-A, U.S.             
          Corporation Income Tax Return, Codes for Principal Business                 
          Activity, for 1990-95 require a corporation to report on its tax            
          return its business activity from which it derives its largest              
          percentage of total receipts, not the business activity                     
          authorized in its articles of incorporation.                                
               We conclude that FabuGlass correctly reported that it was an           
          investment company in 1990-95.                                              
                    c.   Whether FabuGlass Operated in Russia in 1990-94              
               Petitioners contend that FabuGlass was largely an operating            
          company in 1990-94 because it operated in Russia in those years.            
          Petitioner testified that FabuGlass tried to sell armored                   
          vehicles and refrigeration trucks to Russian companies.  However,           
          his testimony on this point was vague.  The record shows that               
          AmRuss, and not FabuGlass, tried to do business in Russia.                  
          Sawyer, who prepared FabuGlass’ original income tax returns for             
          1990-95, testified that he did not know that FabuGlass was trying           
          to do business in Russia, but that AmRuss did try to do business            
          there.  He testified that he and petitioner considered doing                
          business in Russia in 1992 or 1993 on behalf of a company called            
          AmRuss.                                                                     
               Petitioners contend that Exhibit 39-P, a contract dated                
          December 22, 1994, shows that FabuGlass was operating in Russia             
          in 1994.  We disagree.  Exhibit 39-P is a contract in which Bank            
          Baltisky agreed to buy an armored vehicle from AmRuss.  FabuGlass           




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