Transport Labor Contract/Leasing, Inc. & Subsidiaries - Page 18

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          (notice) to petitioner.  In that notice, respondent determined,             
          inter alia, that the section 274(n)(1) limitation applied to the            
          per diem amounts that TLC paid to its driver-employees.                     
               Respondent sent a notice to each of the following trucking             
          company clients of TLC in which respondent determined that each             
          such trucking company client had a deficiency in Federal income             
          tax (tax) for one or more taxable years22 arising out of such               
          trucking company client’s failure to take into account the                  
          section 274(n)(1) limitation23 and with respect to which each               
          such trucking company client commenced proceedings in the Court,            
          as follows:                                                                 
                   Trucking Company Client         Case at Docket No.                 
               John and Kimberly Kohler                 1026-01                       
               (NBS Trucking)                                                         
               Joseph and Barbara Hix                   1062-01                       
               (Joe Hix Trucking)                                                     
               Blachowske Truck Line, Inc.              1107-01                       
               Jones Brothers Trucking, Inc.            1149-01                       
               Lake State Transport, Inc.               1286-01                       
               Schak Trucking Inc.                      1287-01                       
               Donald Fiereck and Beverly               1346-01                       
               Beumer-Fiereck (Parkway Auto                                           
               Respondent conceded the above-referenced cases.  The Court             

               22The record did not disclose the taxable year(s) to which             
          the respective notices issued to certain of TLC’s trucking                  
          company clients pertained.                                                  
               23In the instant case, the 80-percent limitation applies to            
          taxable years ended Aug. 31, 1993, and Aug. 31, 1994, and the 50-           
          percent limitation applies to taxable years ended on or after               
          Aug. 31, 1995.                                                              

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