Eric B. Benson, et al. - Page 7

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               9.  whether Eric, Brad, and Mark received and failed to                
          report distributions from an S corporation in excess of their               
          stock basis;                                                                
               10.  whether Eric, Brad, and Mark are subject to the passive           
          loss rules with respect to passthrough rental losses from an S              
          corporation.                                                                
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts, the supplemental stipulations of facts,           
          the stipulations of settled issues, and the attached exhibits are           
          incorporated herein by this reference.  At the time of filing the           
          petitions, each petitioner’s legal residence was Orinda,                    
          California.                                                                 
          1.  Background                                                              
               Burton O. Benson (Burton) served 9 years as an officer in              
          the U.S. Navy and 23 years as an officer in the U.S. Naval                  
          Reserve, retiring with the rank of Rear Admiral.  Burton earned a           
          B.S. degree in mechanical engineering from the University of                
          Minnesota.  Eric, Mark, and Brad are the sons of the Bensons.6              
          Glendon M. Benson (Glendon) is the elder brother of Burton.                 
          Esther V. Benson (Esther) was the mother of Burton and Glendon.             



               6Eric, Mark, and Brad were born on July 24, 1974, Aug. 26,             
          1976, and Aug. 11, 1981, respectively.                                      





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