Ralph Tashjian - Page 5

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          partner.  On his Form 1040 for 1984, petitioner deducted $141,233           
          attributable to Data Flex.                                                  
               The principal place of business for each of the partnerships           
          was DiRicco’s office in San Mateo, California.  DiRicco formed,             
          organized, promoted, and served as the TMP for Synergistics,                
          Lumenetics, and Data Flex.                                                  
               Synergistics filed a tax return for 1982, which was                    
          processed by the IRS on or about October 19, 1983.  Synergistics            
          was audited for 1982 under the TEFRA audit procedures.  A waiver            
          had been signed extending the period of limitations for                     
          assessment of Synergistics to August 4, 1996.  Lumenetics filed a           
          tax return for 1983.  Lumenetics was audited for 1983 under the             
          TEFRA audit procedures.  Data Flex filed a tax return for 1984.             
          Data Flex was audited for 1984 under the TEFRA audit procedures.            
               By notice of final partnership administrative adjustment               
          (FPAA) mailed to the TMP, dated October 1, 1987, respondent                 
          disallowed a deduction that was reported on the Lumenetics 1983             
          tax return as “marketing expenses”.  In response to the FPAA,               
          DiRicco filed a petition with the Court on January 4, 1988, at              
          docket No. 114-88.  DiRicco also filed petitions with the Court             
          for Synergistics and Data Flex at docket Nos. 24781-87 and                  
          20257-90, respectively.  DiRicco stipulated, on behalf of                   
          Synergistics and Data Flex, that certain TEFRA issues in their              

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