Delaware Corp., et al. - Page 3

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          of certain expenses with respect to certain real property in                
          Virginia Beach, Virginia (Virginia Beach property), constitute              
          for those years constructive dividends to Ms. Havens that Dela-             
          ware Corporation is not entitled to deduct?  We hold that they              
          do.                                                                         
               (3) Is Delaware Corporation entitled for 1994 and 1995 to              
          depreciation deductions with respect to the Virginia Beach                  
          property?  We hold that it is not.                                          
               (4) Do Delaware Corporation’s payments during 1994 of                  
          certain legal fees constitute for that year constructive divi-              
          dends to Mr. Barber that Delaware Corporation is not entitled to            
          deduct?  We hold that they do.                                              
               (5) Do Delaware Corporation’s payments during 1994 and 1995            
          of certain child care expenses constitute for those years con-              
          structive dividends to Mr. Barber that Delaware Corporation is              
          not entitled to deduct?  We hold that they do.                              
               (6) Is Delaware Corporation liable for each of the years               
          1994 and 1997 for the accuracy-related penalty under section                
          6662(a)?  We hold that it is.                                               
               (7) Is Mr. Barber liable for each of the years 1994 and 1995           
          for the accuracy-related penalty under section 6662(a)?  We hold            
          that he is.                                                                 
               (8) Is Ms. Havens liable for each of the years 1994 and 1995           
          for the accuracy-related penalty under section 6662(a)?  We hold            






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