    -38-

I.   Petitioners22

      A.   Burton W. Kanter (STJ report at 18-20)

      Petitioner Burton W. Kanter is an attorney who has

continuously been engaged in the practice of law at Chicago,

Illinois, since about 1956.    He received a J.D. degree from the

University of Chicago in 1952.    From 1952 to 1954, he was a

teaching associate at the University of Indiana Law School.      From

1954 to 1956, he was an attorney-adviser with the U.S. Tax Court

at Washington, D.C.    Since 1956, his law practice has been at

Chicago, Illinois.    His primary expertise is in Federal income

and estate taxation.    Fromand Lisle, followed by findings
of fact concerning IRA and other entities that Kanter employed in
the transactions in dispute (hereinafter sometimes referred to as
Kanter-related entities).
                               -39-

the University of Chicago Law School.    Kanter has lectured and

written extensively in the area of Federal tax law.    He has also

been an active participant in professional bar associations.    For

a number of years, Kanter has been a writer and contributor to

the Journal of Taxation, a national monthly publication devoted

exclusively to Federal taxation.   One of the popular features of

this publication is the Shop Talk section,