Timothy J. Coburn - Page 2

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          references are to the Internal Revenue Code, as amended, and all            
          Rule references are to the Tax Court Rules of Practice and                  
               The parties submitted the instant case fully stipulated,               
          without trial, pursuant to Rule 122.  The parties’ stipulations             
          of fact are hereby incorporated by reference and are found as               
          facts in the instant case.  At the time of filing the petition,             
          petitioner resided in Glastonbury, Connecticut.                             
               During 1996, petitioner received stock of PhyMatrix                    
          Corporation (PhyMatrix) and CareMatrix Corporation (CareMatrix)             
          which had an aggregate value of $1,675,000 at the time of                   
          receipt.1  Petitioner incurred a Federal income tax liability of            
          $621,980 related to the receipt of the stock.2  Petitioner                  
          borrowed from CareMatrix an amount equal to the Federal income              
          tax liability (the loan), pledging 57,248 shares of PhyMatrix               
          common stock (the collateral) as security for the loan.  The loan           
          and the pledge of the collateral are hereinafter collectively               
          referred to as the loan transaction.                                        

               1The record does not reveal the separate amount or value of            
          the CareMatrix stock or the value of the PhyMatrix stock at the             
          time of receipt by petitioner.                                              
               2Petitioner appears to have taken an aggregate basis in the            
          stock of both CareMatrix and PhyMatrix equal to the aggregate               
          $1,675,000 value of these stocks at the time of receipt.                    

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