Menard, Inc. - Page 4

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               penalties for negligence or disregard of rules or                      
               regulations as follows:  MI is liable with respect to                  
               the TMI expenses deduction as disallowed, and S is                     
               liable with respect to the excess TMI expenses                         
               constructive dividend and the constructively received                  
               interest income.                                                       


               Robert E. Dallman, Vincent J. Beres, and Robert J. Misey,              
          Jr., for petitioners.                                                       
               Christa A. Gruber, J. Paul Knap, and Michael Calabrese, for            
          respondent.                                                                 


                       MEMORANDUM FINDINGS OF FACT AND OPINION                        

               MARVEL, Judge:  These cases were consolidated upon motion of           
          the parties for purposes of trial, briefing, and opinion.                   
          Respondent determined deficiencies and section 6662(a)1 accuracy-           
          related penalties with respect to petitioners’ income tax and, by           
          amendment to answer, increased those deficiencies as follows:               
          Menard, Inc., docket No. 673-02                                             
                                        Accuracy-related penalty                      
          TYE Jan. 31         Deficiency             sec. 6662(a)                     
          1998                $8,966,233     $430,414                                 





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




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